final report december 2008 -...

November

In conjunction with

MECKLENBURG COUNTY, NORTH CAROLINA

GENERATION, RECYCLING, AND

DISPOSAL ANALYSIS OF WOOD PALLETS AND UNTREATED WOOD WASTE IN THE

COMMERCIAL AND C&D SECTORS

Final Report

December 2008

MID ATLANTIC SOLID WASTE CONSULTANTS 625 Sawyer Road, New Market, MD 21774 301/607-6428 842 Spring Island Way, Orlando, FL 32828 407/380-8951 3407 Chestnut Street, Camp Hill, PA 17011 717/731-9708

www.mswconsultants.us

ACKNOWLEDGEMENTS

The MSW Team would like to thank the following parties for their assistance during various stages of this project.

Mecklenburg County pallet recyclers, with special thanks to Doug Reiner, Custom Pallet; R.J. Brewer, Metromont; Cheryl Gamble and Bill Hawley, Gamble Pallet Company; Melvin Simpson, Simpson Wood Products, Inc.; and Jim Neal, Neal’s Pallet Company

Builders who participated in two County focus groups (names and companies have been withheld because of an agreement that the participants would remain confidential)

Other recyclers contacted as part of this research, with special thanks to Steve Davis of Union Gypsum and to FCR Recycling

Mike Griffin, President, Griffin Brothers Industries (owner, North Mecklenburg Landfill)

Roger Barnes, Operations Manager, North Mecklenburg Landfill

Shawn Brady, General Manager, Charlotte Division Republic Services (owner, Queen City Transfer Station)

Joe Hack, Solid Waste Services Manager, Mecklenburg County

Terry McCarver, Operations Manager, Foxhole Landfill

Steve Elliott, Yard Waste Operations Manager, Compost Central

Paul H. Martin, Geospatial Information Services, Mecklenburg County

Michael Talbert, Project Manager of Study, Construction and Demolition Waste Recycling, Mecklenburg County

Stewart Espey, Senior Environmental Specialist, Mecklenburg County

Laurette Hall, Environmental Manager, Mecklenburg County

Bruce Gledhill, Mecklenburg County Solid Waste Director

This study would not have been successful without their ongoing cooperation.

Prime Contractor MidAtlantic Solid Waste Consultants, LLC

6225 Sawyer Road, New Market, MD 21774 (301) 607-6428 842 Spring Island Way, Orlando, FL 32828 (407) 380-8951 3407 Chestnut Street, Camp Hill, PA 17011 (717) 731-9708

www.mswconsultants.us

Subcontractor DSM Environmental Services

P.O. Box 2, 15 State Street, Windsor, VT 05089 (802) 674-2840

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Mecklenburg County Pallet/Woodwaste Report i

TABLE OF CONTENTS EXECUTIVE SUMMARY ........................................................................................... 1

ES 1. Introduction ............................................................................................................................1 ES 2. Key Questions.........................................................................................................................1 ES 3. Generation ...............................................................................................................................2 ES 4. Existing Recycling and Reuse Infrastructure......................................................................4

ES 4.1. Wood Pallets.....................................................................................................................4 ES 4.2. Clean Wood......................................................................................................................6

ES 5. Gaps and Strategies ................................................................................................................7 ES 5.1. Small/Damaged Pallets and Pallets from Small Quantity Generators ....................7 ES 5.2. Separation of Clean Wood from Mixed C&D............................................................8 ES 5.3. Separation at the Job Site ...............................................................................................8 ES 5.4. Mixed C&D Processing ..................................................................................................8

ES 6. Development of New Markets for Clean Wood .............................................................11 ES 7. Recommendations ................................................................................................................12

1. INTRODUCTION........................................................................................... 1-1

1.1. Background.......................................................................................................................... 1-1 1.2. Materials Targeted in Study............................................................................................... 1-2 1.3. Report Organization........................................................................................................... 1-4

2. BACKGROUND INFORMATION ................................................................. 2-1

2.1. County Waste Management System................................................................................. 2-1 2.2. Database of Commercial Businesses ............................................................................... 2-2 2.3. Wood Pallet Research ........................................................................................................ 2-4 2.4. Pallet Manufacturing .......................................................................................................... 2-4 2.5. Pallet Recycling ................................................................................................................... 2-7 2.6. Material Densities ............................................................................................................... 2-8 2.7. C&D Waste Composition ................................................................................................. 2-9

3. METHODOLOGY .......................................................................................... 3-1

3.1. Introduction ........................................................................................................................ 3-1 3.2. Commercial Generator Sector Approach ....................................................................... 3-1

3.2.1 Hauler Surveys ............................................................................................................. 3-1 3.2.2 QCTS Survey of Commercial Vehicles .................................................................... 3-2 3.2.3 Commercial Generator Research and Surveying .................................................... 3-3 3.2.4 Telephone Surveys.....................................................................................................3-10 3.2.5 On-site Surveys ..........................................................................................................3-11 3.2.6 InfoUSA Database Accuracy...................................................................................3-13 3.2.7 Targeted Commercial Load Observation ..............................................................3-14

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ii Mecklenburg County Pallet/Woodwaste Report

3.3. Construction and Demolition Sector Approach.......................................................... 3-17 3.3.1 Hauler Surveys ...........................................................................................................3-17 3.3.2 C&D Waste Characterization Study .......................................................................3-17 3.3.3 Builder Focus Groups...............................................................................................3-20

3.4. Recycling Market Research Approach........................................................................... 3-20 3.4.1 Collection Infrastructure Research .........................................................................3-20 3.4.2 Surveys of Market Infrastructure ............................................................................3-21

3.5. Other Information Sources............................................................................................. 3-23

4. WOOD PALLETS AND UNTREATED WOOD............................................. 4-1

4.1. Introduction ........................................................................................................................ 4-1 4.2. Wood Pallet Generation, Recycling and Disposition.................................................... 4-1

4.2.1 Commercial Sector ...................................................................................................... 4-1 4.2.2 C&D Sector ................................................................................................................4-11 4.2.3 Pallet Recycling/Reuse Market Research...............................................................4-16

4.3. Untreated Wood Generation, Recycling and Disposition.......................................... 4-18 4.3.1 Commercial Sector ....................................................................................................4-18 4.3.2 C&D Sector ................................................................................................................4-23 4.3.3 Summary Discussion.................................................................................................4-25

4.4. Transportation and Recycling Market Infrastructure.................................................. 4-26 4.4.1 Collection and Transportation.................................................................................4-26 4.4.2 Pallet Recyclers/Rebuilders......................................................................................4-27 4.4.3 Grinders ......................................................................................................................4-28

4.5. Gap Analysis and Implications of the Pallet Ban ........................................................ 4-29 4.5.1 Landfills.......................................................................................................................4-31 4.5.2 Generators ..................................................................................................................4-32 4.5.3 Commercial Haulers..................................................................................................4-32 4.5.4 Scavengers...................................................................................................................4-33 4.5.5 Pallet Recyclers...........................................................................................................4-33 4.5.6 C&D Processors ........................................................................................................4-34 4.5.7 Clean Wood Markets.................................................................................................4-37

4.6. Conclusion......................................................................................................................... 4-39

5. OTHER TARGETED MATERIALS............................................................... 5-1

5.1. Introduction ........................................................................................................................ 5-1 5.2. Old Corrugated Cardboard ............................................................................................... 5-2

5.2.1 Generation and Recycling in Commercial Waste ................................................... 5-2 5.2.2 Recycling Market Infrastructure................................................................................ 5-4

5.3. Film Plastic .......................................................................................................................... 5-4 5.3.1 Generation and Recycling in Commercial Waste ................................................... 5-4 5.3.2 Disposal in C&D Waste Stream................................................................................ 5-6 5.3.3 Recycling Market Infrastructure................................................................................ 5-6

5.4. Vinyl Siding.......................................................................................................................... 5-7

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Mecklenburg County Pallet/Woodwaste Report iii

5.4.1 Disposal in C&D Waste Stream................................................................................ 5-7 5.4.2 Recycling Market Infrastructure................................................................................ 5-8

5.5. Gypsum Drywall................................................................................................................. 5-8 5.5.1 Disposal in C&D Waste Stream................................................................................ 5-8 5.5.2 Recycling Market Infrastructure................................................................................ 5-9

5.6. Asphalt Roofing................................................................................................................ 5-11 5.6.1 Disposal in C&D Waste Stream..............................................................................5-11 5.6.2 Recycling Market Infrastructure..............................................................................5-11

5.7. Conclusion......................................................................................................................... 5-13

APPENDIX A – PALLET REFERENCE

APPENDIX B – COMMERCIAL GENERATOR SURVEY INSTRUMENT

APPENDIX C – QCTS COMMERCIAL WASTE OBSERVATION DATA

APPENDIX D – NAICS CODE ASSIGNMENTS

APPENDIX E – HAULER SURVEY AND RESPONSES

APPENDIX F – MECKLENBURG COUNTY C&D WASTE CHARACTERIZATION RESULTS

APPENDIX G – BUILDER FOCUS GROUP NOTES

List of Figures

Figure 2-1 Disposition of Recycled Pallets, 1999 .................................................................................... 2-8 Figure 3-1 Expected Pallet/Clean Wood Generation by Industry (No. of Businesses) .................... 3-8 Figure 3-2 Expected Pallet/Clean Wood Generation by Industry (Employment)............................. 3-9 Figure 4-1 & Figure 4-2 Pallets Awaiting Collection............................................................................. 4-4 Figure 4-3 Pallets as a Percent of Disposed Commercial Waste ........................................................... 4-9 Figure 4-4 Proportion of Waste Received at QCTS.............................................................................. 4-10 Figure 4-5 Mecklenburg County Pallet Disposition and Recycling Summary................................... 4-17 Figure 4-6 Clean Wood as a Percent of Disposed Commercial Waste .............................................. 4-22 Figure 4-7 Mecklenburg County Clean Wood Disposition and Recycling Summary ..................... 4-25 Figure 4-8 Pallet Collection and Transportation at Surveyed Businesses .......................................... 4-26 Figure 4-9 Recovered Wood from C&D Processing Plant (Massachusetts) ..................................... 4-35

List of Tables

Table 1-1 Summary of Targeted Materials by Sector .............................................................................. 1-2 Table 2-1 Mecklenburg County Waste Disposal, FY2005-2007............................................................ 2-2

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iv Mecklenburg County Pallet/Woodwaste Report

Table 2-2 Summary of Mecklenburg County Commercial Businesses................................................. 2-3 Table 2-3 Top 10 Pallet Sizes in North America in 2000 ....................................................................... 2-6 Table 2-4 Average Weight of Medium Duty 48 x 40 Pallets.................................................................. 2-7 Table 2-5 Survey Data Units and Conversion Factors............................................................................ 2-9 Table 2-6 Targeted Materials Disposed in C&D Waste Stream .......................................................... 2-10 Table 3-1 Mecklenburg County Businesses Likely to Generate Pallets/Wood................................... 3-5 Table 3-2 Mecklenburg County Businesses that Possibly Generate Pallets/Wood............................ 3-6 Table 3-3 Mecklenburg County Businesses not Surveyed...................................................................... 3-7 Table 3-4 Research Methods for Commercial Sub-Sectors.................................................................... 3-9 Table 3-5 Summary of Commercial Generator Phone Surveys........................................................... 3-11 Table 3-6 Summary of Phone and On-site Survey Responses............................................................. 3-12 Table 3-7 Comparison of On-site Surveys and Total Likely Generator Businesses in Mecklenburg

County................................................................................................................................................... 3-15 Table 3-8 Visual Survey Waste Generation ............................................................................................ 3-16 Table 3-9 Mecklenburg County C&D Waste Composition Summary ............................................... 3-19 Table 3-10 Summary of Pallet/Wood Market Infrastructure Participants......................................... 3-22 Table 4-1 On-Site and Telephone Surveys of Likely Pallet Generators ............................................... 4-2 Table 4-2 Phone Survey of Possible Pallet Generators........................................................................... 4-2 Table 4-3 Generator Coefficients of Likely Pallet Generators Based on On-site Surveys

(pallets/employee/year)........................................................................................................................ 4-4 Table 4-4 Generator Coefficients of Possible Pallet Generators Based on Phone Surveys

(pallets/employee/year)........................................................................................................................ 4-5 Table 4-5 Pallet Generation from Likely Pallet Generators Based on On-site Surveys (No. of

Pallets) ..................................................................................................................................................... 4-6 Table 4-6 Pallet Generation from Possible Pallet Generators Based on Phone Surveys (No. of

Pallets) ..................................................................................................................................................... 4-6 Table 4-7 Total Pallet Generation in the Commercial Sector ................................................................ 4-8 Table 4-8 Summary of Commercial Waste Deliveries to QCTS ......................................................... 4-10 Table 4-9 Wood Pallets in C&D Waste Stream ..................................................................................... 4-12 Table 4-10 Characterization of Wood Pallets in C&D Loads.............................................................. 4-13 Table 4-11 Summary of C&D Debris Deliveries to QCTS.................................................................. 4-14 Table 4-12 Estimated Annual Pallet Recycling by Mecklenburg County Infrastructure ................. 4-17 Table 4-13 Mecklenburg County Pallet Disposition and Recycling Summary ................................. 4-18 Table 4-14 Survey Results of Likely Clean Wood Generators............................................................. 4-19 Table 4-15 Survey Results of Possible Clean Wood Generators......................................................... 4-19 Table 4-16 Generator Coefficients of Likely Wood Generators Based on On-site Surveys

(lbs/employee/year)............................................................................................................................ 4-21 Table 4-17 Wood Generation from Likely Generators Based on On-site Surveys (tons)............... 4-21 Table 4-18 Summary of Commercial Debris Deliveries to QCTS...................................................... 4-23 Table 4-19 Clean Wood in C&D Waste Stream .................................................................................... 4-24 Table 4-20 Summary of Clean Wood in C&D Debris Deliveries to QCTS...................................... 4-24

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Mecklenburg County Pallet/Woodwaste Report v

Table 4-21 Mecklenburg County Clean Wood Disposition and Recycling Summary...................... 4-25 Table 5-1 Surveys of OCC Generation Among Likely Pallet/Clean Wood Generators ................... 5-2 Table 5-2 OCC Generator Coefficients Based on On-site Surveys of Likely Pallet Generators

(lbs/employee/year).............................................................................................................................. 5-3 Table 5-3 OCC Generation among Likely Pallet Generators Based on On-site Surveys (tons) ...... 5-3 Table 5-4 Generation of Film Plastic Among Likely Pallet/Wood Generators ................................. 5-4 Table 5-5 Film Plastic Generator Coefficients from Likely Pallet Generators Based on On-site

Surveys (lbs/employee/year) ............................................................................................................... 5-5 Table 5-6 Film Plastic Generation from Likely Pallet Generators Based on On-site Surveys (tons) 5-

5 Table 5-7 Film Plastic in C&D Waste Stream.......................................................................................... 5-6 Table 5-8 Vinyl Siding in C&D Waste Stream ......................................................................................... 5-7 Table 5-9 Gypsum Drywall in C&D Waste Stream................................................................................. 5-9 Table 5-10 Asphalt Roofing in C&D Waste Stream ............................................................................. 5-11

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vi Mecklenburg County Pallet/Woodwaste Report


Mecklenburg County Pallet/Woodwaste Report 1

EXECUTIVE SUMMARY

ES 1. INTRODUCTION

In late 2005, House Bill (HB) 1465 was ratified by the General Assembly of North Carolina and signed into law to add wood pallets to the list of materials that are banned from disposal in the state’s municipal solid waste (MSW) landfills. The MSW landfill ban on pallets as described in HB 1465 is scheduled to go into effect on October 1, 2009.

To assess the potential impact of the pallet ban, and to improve its understanding of the management and potential for increased diversion of wood pallets and clean wood, Mecklenburg County issued Request for Proposals (RFP) 269-2007-134 in November 2006. The County subsequently retained the Project Team of MidAtlantic Solid Waste Consultants (MSW Consultants) and DSM Environmental Services (DSM) (collectively, MSW Team) to perform a comprehensive analysis of pallet and untreated wood waste disposal and reuse/recycling in Mecklenburg County.

Wood Pallets Clean Wood

The final project approach encompassed both the commercial waste stream and the construction and demolition (C&D) waste stream generated within the County, and also added old corrugated cardboard (OCC), plastic film, gypsum drywall, vinyl siding, and asphalt shingles to the scope of the study. Research methods used in the study included analysis of existing County data and business database resources, disposal site sampling of commercial and C&D wastes, on-site and telephone surveys of commercial generators, hauler interviews, focus groups of builders, phone and in-person meetings with recycled material markets, and research into the performance and dynamics of related case studies of diversion programs and strategies targeting these materials that have been implemented elsewhere within the industry.

ES 2. KEY QUESTIONS

This research effort sought to provide defensible data to answer the following questions relating to diversion of wood pallets and untreated wood waste in Mecklenburg County:

EXECUTIVE SUMMARY

2 Mecklenburg County Pallet/Woodwaste Report

Generation (SUPPLY): How many pallets, and what types (size, use, condition) of pallets, are generated in Mecklenburg County currently? Are these pallets being generated in the commercial waste stream, the C&D waste stream, or both? How much clean, untreated wood waste is being generated in the County’s commercial and C&D waste streams?

Existing Reuse, Recycling, and Disposal (SUPPLY): What is currently happening to the wood pallets and clean wood being generated in commercial and C&D waste in Mecklenburg County? How many pallets are being recovered for reuse by pallet remanufacturers, and how much clean wood – either directly from commercial or C&D generators, or else un-reusable wood pallet scrap – is being beneficially recovered? Conversely, how many pallets and what quantity of clean wood is being discarded in municipal solid waste (MSW) or C&D landfills?

Existing Collection and Recovery Infrastructure (DEMAND): What organizations– collectors, remanufacturers, wood grinders, and others – currently make up the infrastructure for reuse, recycling, and recovery of wood pallets and clean wood, and what volume of materials are they handling currently? To the extent there are large quantities of wood pallets and clean wood waste that are not currently being recovered for beneficial reuse, what are the shortfalls, or gaps, of the existing infrastructure?

Strategies for Increasing Diversion (SUPPLY and DEMAND): To the extent the current infrastructure for separating, collecting, reusing, remanufacturing, recycling, or otherwise beneficially recovering wood pallets and clean wood is deficient in one or more areas, what strategies exist to bolster this infrastructure and increase diversion of wood pallets and clean wood waste?

This executive summary seeks to answer these questions in summary fashion. Note that this executive summary focuses predominantly on wood pallets and clean wood waste. Other materials – old corrugated cardboard (OCC), plastic films, gypsum drywall, vinyl siding, and asphalt shingles – were peripherally investigated as part of this project. Detailed information about these other materials can be found in Section 5 of the full report.

ES 3. GENERATION

A combined 258,500 tons of wood pallets and clean wood were found to be generated in Mecklenburg County. Notable breakdowns of this figure include:

Pallets: Over 7.6 million pallets, or 190,000 tons, were generated in the County. Fifty-six percent, or almost 4.3 million pallets, were generated by large chain stores and retailers with the ability to manage pallets through internal logistics systems that allowed for backhaul of pallets from individual outlets to central warehouses and distribution centers (which in turn dealt directly with remanufacturers). These pallets were considered to be in use, and were not researched further as part of this study. Another 2.6 million pallets (34 percent) were aggregated by individual commercial businesses and hauled (usually by a third party hauler) directly to a pallet remanufacturer for reuse. The remaining ten percent of pallets were disposed, with a slightly higher number being disposed in MSW landfills (generated by commercial businesses) than in C&D landfills (generated by C&D-related activities). Figure ES-1 provides a breakdown by industry of the origin of almost 76,000 tons – 3.14 million pallets – generated within the commercial sector.

EXECUTIVE SUMMARY


Figure ES-1 Commercial Sector Wood Pallet Generation* by Industry 75,960 tons (3.14 million pallets)

* Excludes back-hauled pallets

Clean Wood: Over 68,000 tons of clean wood was found to be generated in the County. Unlike pallets, which are generated throughout the commercial and C&D sectors and may flow through a number of parties on their way to reuse, recycling and disposal, clean wood was almost entirely generated in the C&D waste stream, and disposed as part of C&D waste. Over 62,000 tons of clean wood (91 percent) was generated in the C&D stream and was disposed in a C&D landfill.

Figure ES-1 presents a visual summary of wood pallet and clean wood generation and disposition, and detailed data are shown in Table ES-1.

EXECUTIVE SUMMARY


Figure ES-2 Mecklenburg County Wood Pallet and Clean Wood Generation and Disposition

Table ES-1 Mecklenburg County Wood Pallet and Clean Wood Generation and Disposition

Pallets Clean Wood

Current Disposition Number Tons Percent Tons Percent

Disposed in MSW LF 445,102 11,128 5.8% 3,853 5.7%

Disposed in C&D LF 310,593 7,765 4.1% 62,252 91.3%

Recycled (including grind) 2,594,894 64,872 34.1% 2,084 3.1%

Backhaul for Recycle 4,263,106 106,578 56.0% N/A N/A

Total 7,613,695 190,342 100.0% 68,189 100.0%

ES 4. EXISTING RECYCLING AND REUSE INFRASTRUCTURE

The current infrastructure for pallet and clean wood recycling spans numerous organizations, public and private, large and small. This study found the following infrastructure to be in place in Mecklenburg County to manage wood pallets and clean wood.

ES 4.1. WOOD PALLETS Commercial Collection: Wood pallets are collected and transported to remanufacturers

by a surprising range of entities. Not surprisingly, commercially licensed haulers collect and deliver the largest number of pallets, through standard roll-off collection service.

EXECUTIVE SUMMARY


Commercial haulers were found to collect and deliver 80 percent of the pallets recycled directly from their point of generation.

Unregulated Collection: Interestingly, a majority of pallet generating businesses in Mecklenburg County (estimated at 63 percent) are served not by licensed commercial haulers, but by a large network of unregulated scavengers who collect small quantities of pallets (and sometimes OCC and other valuable recyclables) from local small quantity generators who might not otherwise generate enough pallets to warrant source separation and recycling by commercial haulers. One pallet recycler estimated that there may be over 100 such entities operating in the County. As shown in Figure ES-3, these scavengers use pick-up trucks to collect wood pallets for which it was reported they are paid between $1 and $2 by local remanufacturers. Although these scavengers predominantly target the most common (and therefore most reusable) sized pallets and pallets that exceed 40 inches in at least one diameter, some businesses reported that they have made arrangements with these small haulers to accept off-spec and damaged pallets as a condition of taking the desirable, standard-size pallets. Given the extremely high recycling rate for pallets that already exists, this network of small collectors is very effective at aiding the beneficial recovery of wood pallets in Mecklenburg County.

Figure ES-3 Unregulated Hauler of Wood Pallets

Pallet Remanufacturers: Mecklenburg County is home to 16 pallet remanufacture/recycling businesses. These establishments sort, grade, rebuild, and resell pallets to a wide range of customers spanning many industries. As described above, the County’s pallet remanufacturers are currently estimated to manage roughly 7 million pallets (over 4 million of which are from distribution centers and warehouses that backhaul pallets and employ the pallet remanufacturer directly). All of the pallet remanufacturers surveyed indicated having the capacity for taking on additional pallets of suitable dimension. The relatively small percentage of pallets not being recovered from commercial generators at the current time – roughly 11,000 tons – are those generated at

EXECUTIVE SUMMARY


small quantity generators that are not targeted by the scavenging community because they are highly damaged and/or smaller in size than “standard” pallets.1

Grinders: There are four operations in Mecklenburg County, including the County’s site at the Foxhole Landfill and three pallet remanufacturers, that grind clean wood and that therefore accept wood pallets for grinding. Much of the pallet (and clean wood) grind is currently being transported locally to a relatively saturated boiler fuel market. The companies grinding pallets were generally found to be doing so only to avoid the disposal fee for their own un-recoverable pallets; these companies charged for grinding pallets from other generators, essentially to cover the cost of grinding plus transporting ground wood to boiler fuel markets. One grinder reported having markets for up to 10,500 tons of additional clean wood (outside of boilers), and the County’s Compost Central site indicated mulch sales could be increased by approximately 2,000 tons per year above current levels. Available capacity to absorb ground clean wood therefore appears to total roughly 12,500 tons annually.

ES 4.2. CLEAN WOOD As illustrated, clean wood is predominantly generated in the C&D waste stream. Ultimately, to the extent clean wood is source separated, it is delivered to the same grinders along with pallets for grinding and use in local boiler fuel and mulch markets. However, relatively little clean wood is being source separated at the current time. Clean wood recycling infrastructure includes:

Source Separation by Generators: Builder focus groups conducted as part of this project yielded excellent insight into the barriers to increasing clean wood recovery from construction sites. Barriers to pallet and clean wood recycling were numerous, and included (roughly in order of priority): builders of residential homes believe that recycling costs more than traditional disposal methods, space constraints for additional containers for source separation, limited ability to effectively manage recycling with subcontractors, insufficient industry recycling incentives (such as LEED2 certified projects or owner requirements for on-the-job recycling) especially for residential builders, and no support from local haulers for job site recycling. There was consensus that any initiatives to improve pallet and/or clean wood recycling from C&D sites would have to be mandatory for all builders to assure a level playing field.

Collection: Unlike pallets, collection and transportation of clean wood from generators – whether commercial or C&D – is generally only provided by commercial haulers for customers who generate full loads. The clean wood therefore incurs a lower tip fee compared to disposal, making it worthwhile for the generator. With no direct payments

1 One of the medium sized pallet recyclers reported that they recycle the following size pallets (in inches): 48x40, 48x48, 44x44, 45x45, and 36x36. Because the “standard” pallet (often called a “GMA” pallet because it is the standard size for Grocery Manufacturers Association stores) is typically a 48x40 inch pallet, any pallet with one dimension equal to, or longer then, 40 inches can generally be used to refurbish other pallets – especially the standard pallet. As these sizes listed above indicate, pieces from a 48x48 pallet can be used to refurbish all of the pallet sizes that this pallet recycler refurbishes, while a 36x36 pallet can only be used to refurbish the same or a smaller pallet. For this reason, pallets smaller than 48x40 are the most difficult to recycle, and therefore are the pallets most likely to be thrown away. 2 Leadership in Energy and Environmental Design (LEED)

EXECUTIVE SUMMARY


for delivery of clean wood, the informal community of pallet scavengers is not interested in this material.

Grinders: Grinders are discussed above.

Wood Chip Users: Local companies who purchase ground wood chips for use as boiler fuel include Bowater, which pays $6 to $7 per ton (and is 28 miles distant), Chester Wood Products paying $14 per ton (40 miles), and Stone paying $14 per ton (110 miles). These users were found to have access to their full capacity for clean wood chips from current suppliers of clean wood chips. Several grinders reported using wood chips for mulching products.

ES 5. GAPS AND STRATEGIES

Mecklenburg County clearly sustains a robust pallet recycling infrastructure, one that has the capacity to accept additional pallets for reuse to the extent such pallets can be collected and delivered. Conversely, if all of the clean wood that is currently being disposed – over 62,000 tons – were suddenly diverted, current processors and end markets could not absorb this material. There are significant barriers to recovering a large fraction of the 62,000 tons that are currently generated.

This section attempts to concisely identify specifically where wood pallet and clean wood waste recovery face challenges, and to what degree such challenges can be overcome. Such “gaps” are described below.

ES 5.1. SMALL/DAMAGED PALLETS AND PALLETS FROM SMALL QUANTITY GENERATORS

Given the already high recycling rate of reusable pallets, as well as the record for limited enforcement of disposal bans for other materials, it is not expected that an MSW landfill disposal ban on pallets will markedly change the current flow of used pallets. In other words, roughly the same number of wood pallets will continue to be disposed after the ban is implemented. However, if enforcement of the disposal ban is strictly enforced, it will impose additional costs on very small quantity generators of wood pallets, as well as on businesses that generate primarily small and/or damaged pallets. Scavengers do not take such pallets, but currently these generators can dispose of small/damaged pallets in their commercial waste. Strict enforcement might require such generators to incur extra cost for separate collection service for pallets. It is likely that the existing network of commercial haulers and unregulated scavengers would develop appropriate service rates to provide the required collection services.

As stated above, the existing pallet recycling infrastructure can absorb as many standard pallets as become available to the system. Further, even if every one of the 445,000 pallets (11,000 tons) currently being disposed in MSW landfills were too small or damaged for reuse, and were therefore diverted and delivered to local grinders, our research indicates that there are sufficient markets to absorb this volume of wood chips.

EXECUTIVE SUMMARY


ES 5.2. SEPARATION OF CLEAN WOOD FROM MIXED C&D With over 62,000 tons of clean wood being disposed in the C&D waste stream, it would appear that this stream could be aggressively targeted for recovery. However, before more clean wood can be recovered, two things must happen:

1) It must be separated at the point of generation (the job site), or it must be separated at a processing facility, and

2) There must be one or more markets to absorb increased volumes of clean wood at a rate which is economically competitive with existing options (i.e., C&D landfill disposal).

Clean wood (and pallets) can be separated from C&D debris in one of two ways. Source separation – whereby builders place a separate container on their job site exclusively for clean wood – would assure the cleanest material, and also provide access to the widest number of potential markets for clean wood. Alternatively, many regions of the country have seen the establishment of mixed C&D processing facilities that accept mixed loads of C&D wastes, and use a range of conveyors, screens, separation equipment, and sorting personnel to recover wood and other materials (typically concrete, metals, and OCC). Both of these recovery strategies for clean wood are problematic.

ES 5.3. SEPARATION AT THE JOB SITE Builders who participated in focus groups as part of this study indicated numerous barriers to on-site recycling. Lining up markets and containers, sequencing material recycling, supervising sub-contractors and training employees to recycle all add time and cost, and also require space at the job site. At a minimum, any requirements imposed by the County to require source separation at the job site would be likely to encounter resistance from the building community because of the increased costs that such requirements would impose. However, residential builder feedback also suggests that as long as any such requirements are mandatory and apply equally to all builders, then the impact on competition for building projects will be minimized.

ES 5.4. MIXED C&D PROCESSING In some parts of the country, mixed C&D processing facilities have been developed to increase diversion of wastes from the C&D stream. These facilities typically require high capital investment in grinders, conveyors, screens and trommels, and sorting stations needed to process a high volume waste stream. These facilities accept and process mixed loads of C&D, as shown in Figure ES-3, and separate recoverable materials.

In Mecklenburg County, there are several businesses that are recovering some C&D from mixed C&D loads. However, these businesses are driven primarily by builders seeking LEED certification, and employ primarily hand sorting of materials in their own enclosed buildings. These facilities are not considered large scale mixed C&D processors and have a limited throughput (and target only the easiest materials to recover).

EXECUTIVE SUMMARY


Figure ES-4 Mixed C&D Awaiting Processing

The quantity of clean wood and other potentially recyclable materials in C&D waste suggest that establishment of C&D processing would greatly increase recovery. However, of equal importance, establishment of C&D processing capacity involves capital investment and increased operating costs that must be considered within the local disposal and recycled material market dynamics. While it was beyond the scope of this project to develop a County-specific solution for C&D processing infrastructure that would significantly increase recycling of clean wood as well as other C&D materials, experiences with C&D recovery in other geographic markets and under other regulatory conditions across the nation suggest certain important characteristics for such projects:

Regulatory Mandates: State-level mandates to process C&D prior to disposal, or else meet high recycling goals, drive the development of a C&D processing infrastructure in many regions of the country. In some cases, individual jurisdictions have also implemented local ordinances that make C&D diversion from construction sites a requirement of the permitting process, thereby establishing a strong incentive towards compliance (e.g., occupancy permit is not issued until C&D diversion is documented). Neither the State of North Carolina nor Mecklenburg County have such regulatory mandates at this time.

High-Cost Local Disposal Markets: Often, the reason for governmental mandates in these regions is that disposal capacity is becoming scarce, and local disposal tip fees are high. Case studies in Massachusetts, California, and South Florida are mentioned in the body of the report, and in each of these cases disposal tip fees are at $75 per ton or higher because of the scarcity of local landfill airspace. The local disposal tip fee is important because it establishes the opportunity cost of simply disposing of C&D without

EXECUTIVE SUMMARY


processing. Higher cost disposal makes C&D processing and recovery more economically attractive. In the Mecklenburg County region, fees range from approximately $35 to $45 per ton. These tip fees may be too low to encourage capital investment for high throughput C&D processing facilities.

Moderate Recovery Rates: Excluding the large fraction of fines and ground C&D debris that comes out the back of a typical C&D processor, recovery rates of C&D materials are well below 50 percent, and in many cases are closer to 20 or 30 percent (or lower). Because most clean wood applications have very low tolerances for painted, stained and especially pressure treated wood, sorters must err on the side of caution and let much clean wood go as potential painted or stained wood. Figure ES-4 shows the output of the wood sorting line at a C&D processor in Massachusetts. This picture shows the combination of clean wood with engineered and painted/stained wood, all of which is ground for Northeast boiler fuel markets.2

Figure ES-5 Recovered Wood from Mixed C&D Processing

Based on the Project Team’s experience with these C&D processing case studies, it is believed that actual clean wood recovery from C&D processing in Mecklenburg County would be closer to the 20 percent range of all clean wood in the C&D waste stream. Further, the cost 2 The primary implication of mixing clean wood with painted/stained/engineered wood in a boiler fuel application is that the ash from these facilities must be landfilled. Ash from incinerated clean wood can be land applied at a much lower cost or even sold as a soil amendment. The boiler operators in and around Mecklenburg are currently able to source clean wood chips, so it is unlikely they would convert to a feedstock comprised of painted/stained/engineered wood that would generate ash requiring more costly disposal.

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to divert this material would be close to double the current local disposal rates available in the County. It is hypothesized that the development of both C&D processing infrastructure and the establishment of regulatory mandates that would require the private building and hauling community in Mecklenburg County to use such a higher cost disposal option would be politically challenging.

ES 6. DEVELOPMENT OF NEW MARKETS FOR CLEAN WOOD

Mecklenburg County’s local market was found to be able to absorb roughly 12,500 additional tons of clean wood among its existing infrastructure for grinding and beneficial reuse (as either boiler fuel or mulch). However, if the MSW landfill ban on wood pallets is strictly enforced (driving up to 11,000 tons of wood pallets to grinders), and the County ultimately does pursue a strategy of mixed C&D processing (resulting in 12,500 tons of clean wood generated by C&D generators, plus additional painted/stained/engineered wood), additional markets will be needed to absorb another 11,000 tons of clean wood. This gap is shown in Figure ES-5.

Figure ES-6 Maximum Potential Gap in Markets for Clean Wood

Should it ever become necessary to close the gap as shown above, there are a variety of options that may be considered. These include new bio-fuel boiler demand, wood pellet manufacturing, erosion control fabrics, particle board; and mulch (including colorized mulch and compost). Experience in other geographic regions suggests significant technical and/or lead time issues associated with developing wood pellet manufacturing, erosion control, and particle board markets. Our best estimate is that the establishment of C&D processing to recover clean wood, as well as associated regulations that would compel use of such a facility despite lower-cost local disposal options, would have to either involve the development of new bio-fuel combustion capacity and/or a significant increase in the demand for compost and colored mulch.

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ES 7. RECOMMENDATIONS

The data above have been provided to highlight the most critical findings about wood pallets and clean wood waste. The full study also provides additional findings about the generation and recycling of old corrugated cardboard, film plastic, gypsum drywall, vinyl siding, and asphalt shingles. The bullets below summarize the recommendations that emerge from the extensive research conducted for this project:

Wood Pallets: Mecklenburg County is home to an extensive infrastructure for the collection, remanufacture, and recycling of wood pallets. This infrastructure already achieves extremely high recycling/reuse rates for pallets. In the absence of strict enforcement of the pallet ban when it goes into effect, it is unlikely there will be any material changes to the flow of pallets. For this reason, it is recommended that the County take no action in advance of the pallet ban beyond its customary role of recycling advocacy and public education messaging.

Clean Wood: The high recycling rate for pallets results in a significant supply of odd size and un-reusable pallet pieces which are currently ground to produce clean wood chips. These wood chips, combined with clean wood grinding by the County, produce enough ground wood to supply existing markets. For this reason the County does not currently have the demand to significantly expand clean wood recycling and reuse. While existing grinders can handle any excess pallet scrap that may result from the pallet ban, and the local market for mulch and compost appears capable of absorbing some additional clean wood, significant increases in clean wood recycling and reuse must be preceded by development of a market for such material. This market could take the form of one or more new bio-fuel combustion facilities capable of accommodating wood chips containing painted/engineered wood, or possibly by luring a large scale particle board manufacturer to the area capable of using ground wood chips. In the absence of significant new demand for wood chips, neither a ban on clean wood disposal nor development of mixed C&D processing capacity is recommended. Rather, the County’s near term efforts should focus on continued public education about its existing clean wood recycling infrastructure, as well as on development of additional mulch or compost markets.

OCC: This project only evaluated OCC recycling among large businesses that also generate pallets, rather than the entire universe of commercial businesses. These large-pallet-generating businesses also tend to be large-quantity OCC generators. The recycling rate of OCC is already high among these businesses. However, several site visits as well as several hundred phone survey responses suggest that there is still a significant quantity of OCC being disposed among those businesses that were classified as Possible pallet generators. These Possible pallet generators include almost 19,000 mid-sized and smaller businesses of all types (and, the 13,000 smallest businesses in the County were not surveyed for this project). The County should continue to target commercially generated OCC for increased recycling through available means.

Plastic Films: Given the challenges associated with acquiring additional source separated, uncontaminated plastic films from either the commercial or C&D sectors, it does not appear that the County can or should expend significant resources to improve film plastic recycling at this time. Further, markets for the dirtier film that is generated at

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C&D sites – limited in the best of times – have disappeared in the current economy. The County should therefore continue in its role as a clearinghouse for recycling market information, informing businesses especially of film recycling opportunities in the course of its ongoing public education campaigns.

Asphalt Shingles: No known asphalt shingle recycling is currently occurring in Mecklenburg County. However, asphalt shingle recycling presents a legitimate opportunity for expanding C&D recycling. Asphalt shingles are often kept separate at the construction site, and markets for ground asphalt have been proven viable in other states that have addressed and overcome certain technical barriers. One such potential barrier to expanded asphalt shingle recycling (in addition to relatively low tipping fees at County landfills) is the potential risk of asbestos contamination in the material, and from the ensuing requirements that may be imposed on shingle recyclers by state or local regulatory agencies. Given the potential for uncertainty introduced by unresolved health issues related to grinding of asphalt shingles for recycling, the Mecklenburg County Solid Waste Department should actively engage appropriate County and State agencies to make a determination on what processes, if any, must be implemented to establish recycling of the material. Once local and state regulatory policies have deemed asphalt shingles safe to recycle, the County can begin in earnest the process of establishing specifications for the use of recycled asphalt shingles (RAS) in pavement and other applications, as well as subsequent market development activities.

Gypsum Drywall: Mecklenburg County is fortunate to have one of the innovators in gypsum drywall recycling – Union Gypsum – operating a recycling plant in close proximity to the County. Yet potential barriers nonetheless exist to expanding gypsum recycling. Given the potential for increased hydrogen sulfide generation associated with gypsum disposed in landfills, it is recommended that the County closely monitor the on-going research effort that several northeastern states are funding to determine the exact cause of hydrogen sulfide emissions, while simultaneously supporting the efforts of Union Gypsum to expand alternative uses for ground gypsum drywall. The County should also initiate discussions with new gypsum drywall manufacturers in the County with respect to the potential for these facilities to accept gypsum drywall waste for recycling.

Vinyl Siding: Although vinyl siding recycling programs are in place elsewhere in North Carolina, the small quantity of this material in the C&D waste stream diminishes the focus on this material for recycling Mecklenburg County. Establishment of a vinyl siding recycling program would likely require active involvement by the County in establishment of a central collection, inspection/cleaning, and densification location. It would appear that this opportunity should be placed on the bottom of the County’s list of recycling priorities until such time as a vinyl recycler moves into the region independently.

Mixed C&D Processing: Companies that recycle some of the components of the C&D waste stream (e.g., metals, corrugated cardboard, concrete, untreated/unpainted wood, gypsum wallboard) require that the materials be delivered relatively free of contaminants. This requires that builders and contractors either sort the materials at the building/demolition site or have them sorted elsewhere by a facility that is set-up to do so (mixed C&D processing).

There are two levels of processing. The first is a relatively low-throughput method which requires less capital equipment. With these low throughput systems, selected C&D loads

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that are rich in recyclable materials are basically dumped on the ground and sorted by hand, sometimes with the assistance of a front loader. In the Mecklenburg region, there are currently three companies that provide this lower level of processing. A high throughput system targeting any and all loads of C&D waste requires much more capital investment to purchase sorting systems consisting of magnets, screening and conveyance systems, sorting stations and other equipment. In return, these systems are capable of processing a much larger quantity of material. There are currently no high throughput systems in the region. This is likely due to a combination of factors, including the relatively low disposal costs for C&D wastes, the number and location of disposal facilities, the market demand for such services, and the absence of recycling mandates.

Mecklenburg County should support and promote the mixed-waste processors already operating in the County along with the other markets for source-separated materials. The County should continue to monitor the state and costs of high-throughput technologies and evaluate if such systems would be viable in the future. At the appropriate time, the County could consider what policies it might implement to facilitate the development of high-throughput systems.

Mecklenburg County Pallet/Woodwaste Report 1-1

1. INTRODUCTION

1.1. BACKGROUND

In late 2005, House Bill (HB) 1465 was ratified by the General Assembly of North Carolina and signed into law to add wood pallets to the list of materials1 that are banned from disposal in the state’s municipal solid waste (MSW) landfills. As defined in HB 1465, wood pallets are considered “wooden object[s] consisting of a flat or horizontal deck or platform supported by structural components that is [sic] used as a base for assembling, stacking, handling, and transporting goods." HB 1465 further allowed wood pallets to be properly disposed of in a landfill that is permitted to only accept construction and demolition (C&D) debris. However, a county or a city may petition for a waiver if they can show that prohibiting the disposal of wood pallets in an MSW landfill would constitute an economic hardship. The MSW landfill ban on pallets as described in HB 1465 is scheduled to go into effect on October 1, 2009.

Mecklenburg County has a population of approximately 827,000 residents and is home to a thriving business community. Located at the intersection of Interstates 77 and 85, the County is experiencing a high population and economic growth rate within its borders and in surrounding areas. Given that pallet use is believed to be extensive throughout the local business and construction sectors, the County was concerned that the ban on MSW landfill disposal of pallets could create an economic hardship. At a minimum, concern existed that a broad cross section of local businesses would have to incur extra costs to manage damaged or odd-sized pallets that would be destined for disposal. Of equal importance, upholding the ban could potentially require the County itself to incur additional costs to create policies, services, and enforcement capabilities to support the ban.

Although the County’s Solid Waste Management department supports commercial and C&D recycling throughout the County, there existed little quantifiable data about the prevalence of wood pallets and the ways in which end-of-life pallets are currently being managed. To improve its understanding of the wood pallet waste stream, Mecklenburg County issued Request for Proposals (RFP) 269-2007-134 in November 2006 to retain a consultant not only to analyze wood pallets, but also to investigate untreated wood waste (as this material can be recycled/reused in many similar end markets as pallets). The original RFP contained a series of questions to be answered:

How many pallets and how much untreated wood waste generated in Mecklenburg County is being disposed in municipal solid waste and C&D landfills? Describe the size, type, condition, and sources of these discarded pallets and discarded clean wood.

What is the existing infrastructure for the collection, processing and reuse of pallets and clean wood? Can this infrastructure absorb additional quantities? If so, how much more pallets and clean wood could be recycled and why are they not currently being recycled?

1 A previous ban existed on the disposal of used oil, yard waste, white goods, antifreeze, aluminum cans, scrap tires and lead acid batteries from landfills; in addition to wood pallets, HB 1465 also prohibits the disposal of motor oil filters, rigid plastic containers and oyster shells.

1. INTRODUCTION

1-2 Mecklenburg County Pallet/Woodwaste Report

What are the gaps (if any) between scrap pallet and scrap wood supply and demand? What strategies could be applied to reduce or eliminate these gaps?

The County subsequently retained the Project Team of MidAtlantic Solid Waste Consultants (MSW Consultants) and DSM Environmental Services (DSM) (collectively, MSW Team) to perform a comprehensive analysis of pallet and untreated wood waste disposal and reuse/recycling in Mecklenburg County. The MSW Team worked with Mecklenburg County to develop and refine a project approach to analyze wood pallet and untreated wood waste generation, recycling and re-use. Based on input from all parties during the scoping process, this approach ultimately was expanded to encompass several additional elements. These included a full characterization study of the C&D waste stream,2 as well as the inclusion of some other materials that are believed to be recoverable from the waste stream and are often generated by entities that generate pallets and/or untreated wood waste.

The final project approach encompassed both the commercial waste stream and the construction and demolition (C&D) waste stream generated within the County. For purposes of this study, commercial waste was broadly defined to include waste from non-residential businesses, institutions, and industries, but excluding construction and demolition activities.3 Research methods used in the study included analysis of existing County data and business database resources, disposal site visual sampling of commercial and C&D wastes, telephone and on-site surveys of those commercial generators potentially generating pallets, focus groups of builders, and phone and in-person meetings with recycled material markets.

1.2. MATERIALS TARGETED IN STUDY

Table 1-1 summarizes the materials that were ultimately targeted for study. Note that wood pallets and clean wood waste remained the focal point of the analysis; information about the other materials was gathered to the extent it could be obtained in the process of researching potential generators of wood pallets and clean wood waste.

Table 1-1 Summary of Targeted Materials by Sector

Material Definition Commercial Waste Stream

C&D Waste Stream

Wood Pallets Wooden object[s] consisting of a flat or horizontal deck or platform supported by structural components that is used as a base for assembling, stacking, handling, and transporting goods

2 “Mecklenburg County Construction and Demolition Debris Composition Study,” September 2008. 3 A more precise definition of commercial businesses based on North American Industry Classification System (NAICS) codes is provided in Section 2.

1. INTRODUCTION


Material Definition Commercial Waste Stream

C&D Waste Stream

Clean (Untreated) Wood Waste

Non-treated processed wood for building, manufacturing, landscaping, packaging. Examples include dimensional lumber, lumber cutoffs, wood scraps, wood shake roofing, and wood siding. May contain nails or other trace contaminants, although may not be painted, treated, stained or coated in any way. Wood pallets that are too small or too damaged to be repaired/reused are also considered clean wood.

OCC Paperboard containers consisting of Kraft (brown) linerboard with corrugated (fluted medium) fillings. Includes yellow and waxed corrugated boxes and Kraft paper such as bags or wrapping paper.

Film Plastic Any recyclable polyethylene (high density, low density, linear low density) film plastic including sheet plastic, shrink wrap, and some tarping.

Vinyl Siding An engineered product, manufactured primarily from polyvinyl chloride resin, giving vinyl siding its name. Comprised of other ingredients that establish color, opacity, gloss, impact resistance, flexibility, and durability. It is the most commonly installed exterior cladding for residential construction.

Gypsum Drywall Unpainted gypsum wallboard or interior wall covering made of a sheet of gypsum sandwiched between paper layers. Includes used or unused, broken or whole sheets. Gypsum board may also be called sheetrock, drywall, plasterboard, gypsum board, gyproc.

Asphalt Shingles Material that is used for roofing any structure. Examples include composite shingles, attached roofing tar and tar paper, asphalt shingles.

For each of the materials in the above table, the project sought to:

Identify in greater detail the specific commercial sectors from which these materials are being generated, recycled, and disposed, as well as related generator coefficients for use in subsequent analysis and recycling planning efforts;

1. INTRODUCTION


Quantify the amount generated in Mecklenburg County and disposed in MSW or C&D landfills;4

Identify and quantify the capacity of local and regional processors and end markets for these materials;

Identify opportunities for, as well as barriers against, increasing diversion of these materials; and

With regard to wood pallets, describe to what extent the HB 1465 ban on wood pallets in MSW landfills will (or will not) impose economic hardship on County businesses or the County itself.

1.3. REPORT ORGANIZATION

The remainder of this report describes the many facets of research and analysis that were performed to achieve these objectives, and is divided into the following sections:

Section 2 – Background Information: This section provides an overview of Mecklenburg County’s waste management system in terms of programs, material volumes, haulers, and other participants that may be influenced in this study. It summarizes the sources of County business data that were relied upon to inform and guide research into the commercial sector of the County. It provides a general overview of wood pallets, including their manufacture, dimensions, useful life and weight data; and finally references pertinent data from prior waste characterization studies, including the C&D waste composition analysis that was performed in parallel to this project.

Section 3 – Methodology: This project involved numerous tasks to investigate wood pallet and clean wood waste generation, handling, disposal, recycling and reuse. This section summarizes the multiple approaches that were employed to gain a full understanding of the system and to compile defensible data about the quantity and movement of materials. This section describes the following elements of the overall approach:

Commercial Generator Surveying encompassing field observations of commercial waste deliveries at local MSW disposal facilities, as well as telephone and field surveys of commercial generators to compile data about generation and recycling of targeted materials.

Hauler Surveys of both County-licensed haulers and the unregulated businesses involved in collecting wood pallets from County businesses.

C&D Waste Characterization at two County C&D landfills to estimate the quantity of targeted materials in disposed C&D waste.

Focus Group meetings with County builders and contractors to learn about the opportunities and barriers to recycling from residential and commercial construction sites.

4 It should be noted that the Project Team only attempted to quantify total generation and disposal for those generators likely to be generating wood pallets and clean wood, not from all commercial generators.

1. INTRODUCTION


Recycling Infrastructure Research to identify and quantify the capacity for recycling and processing of the materials targeted in the study.

Gap Analysis, a term that is intended to convey the notion that markets for the materials targeted in this study do not have the capacity to receive and process the volume of materials that could potentially be diverted and reused or recycled – hence there is a “gap” in market capacity. The Gap Analysis attempts to tie together the generator research with the recycling infrastructure research to address the existence of any gaps and to discuss how such gaps or other barriers to increased diversion may be overcome.

Section 4 – Wood Pallet and Clean Wood Results: Wood pallets and clean wood are generated by similar types of generators in both the commercial and C&D sectors, and the markets for end use of the two materials overlap. Because these two materials were the focal point of this study, every element of the project approach was designed to flesh out our understanding of the generation, collection, disposal, and recycling/reuse of these materials. The results of our research for these two materials therefore warrants its own section of the report. For both wood pallets and clean wood, this section estimates the amount of material generated as well as pertinent characteristics (e.g., types and sizes of pallets); identification of the material flows to disposal, reuse and recycling; a summary of the current market(s) for recovery of the material; and a discussion of any deficiencies in the current recycled material markets. Finally, this section discusses the “gaps” between current infrastructure and longer term infrastructure needs for increasing diversion of these materials, including a discussion about the likely impact of the HB 1465 pallet ban on local businesses.

Section 5 – Results for Other Targeted Materials: This study targeted additional materials that were researched in conjunction with the wood pallet and clean wood research. This section of the report presents our findings for the other targeted materials.

Appendices: Appendices contain a wide range of field data collection forms, summary data, and other information that may be of interest.

1. INTRODUCTION




2. BACKGROUND INFORMATION

2.1. COUNTY WASTE MANAGEMENT SYSTEM

Mecklenburg County, home to the City of Charlotte and the Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill and Pineville, manages a large integrated waste management system to provide a wide range of collection, recycling and disposal services to its residents and businesses. Each of the incorporated municipalities in the County provide for the collection and disposal of residentially generated waste, although residents in the unincorporated areas subscribe for residential collection with a private hauler. Residential waste is delivered (or caused to be delivered) to the BFI Charlotte Motor Speedway Landfill located in Cabarrus County, where the County has procured disposal capacity until 2012 for the benefit of itself and its incorporated municipalities (which benefit under the terms of an interlocal agreement). Information about generation and recycling of materials from the residential waste stream is available and considered to be highly accurate, given the local government involvement in the management of residential waste.

With the exception of the small businesses serviced by the City of Charlotte and Town of Davidson, all commercial and construction and demolition (C&D) waste generated in the County is collected by one of the private garbage haulers servicing the area. There are currently 28 permitted haulers that provide residential and commercial garbage and C&D debris collection service within the County limits. In addition to the BFI-Speedway Landfill, commercial haulers have several disposal facilities from which to choose for disposal of commercial wastes, including Republic Wastes’ Queen City Transfer Station in Charlotte, and several other landfills and a transfer station in adjacent counties.

The majority of C&D debris is disposed at either the Mecklenburg County Foxhole Landfill at the County’s southern border or at the privately owned North Mecklenburg Landfill in Huntersville. Meaningful quantities of C&D are also delivered to the BFI-Lake Norman C&D Landfill in Lincoln County. Mecklenburg County opened the Foxhole Landfill in the spring of 2000 and although the landfill is permitted to dispose of MSW, due to the contract with Allied/BFI, the Foxhole Landfill is limited to the disposal and recycling of construction and demolition waste and as a public convenience center for solid waste management at this time.

North Carolina regulations also allow certain waste disposal to take place in land clearing and inert debris (LCID) landfills. The North Carolina Department of Environment and Natural Resources (DENR) website shows that Mecklenburg County has 38 LCID landfills open at the current time, although the County identified only six of these as being active. At the outset of this project, County inspectors queried the known LCID landfill operators and determined that these facilities were not receiving meaningful quantities of wood pallets and clean wood. For this reason, these facilities have been omitted from further study.

DENR requires that MSW and C&D disposal facilities report annual disposed quantities by county of origin. Further, Mecklenburg County tracks residential wastes through its contractual arrangements for residential collection. Table 2-1 summarizes the annual waste generation quantities for the most recently reported three years.



Table 2-1 Mecklenburg County Waste Disposal, FY2005-2007

Waste Stream 2005 (1) 2006 (1) 2007 (2)

Residential Waste 348,939 347,460 388,151

Commercial Waste 548,338 570,665 773,106

C&D Debris 388,212 397,232 377,120

Total Waste Disposed 1,285,489 1,315,357 1,538,377 (1) Source: Mecklenburg County Solid Waste Management Plan, 2006-2016, Tables 2.1.2, 2.3.2,

2.3.3, and 2.3.4 (2) Source: FY2007 Data provided by Mecklenburg County.

In 2005, the County performed an analysis of the composition of commercial wastes generated in the County.1 Because it was not possible to obtain access to the BFI-Speedway Landfill to conduct a physical characterization study as part of this effort, the analysis relied on a “desktop evaluation” (i.e., using comparative analysis and estimations rather than field analysis or sorting/weighing). Commercial waste composition was estimated based on commercial waste composition in other similar counties. This “desktop evaluation” suggested the following details about the County’s commercial waste:

According to an analysis of a database of Mecklenburg County commercial businesses developed by business marketing company InfoUSA,2 there were 33,455 establishments with total employment of 534,858;

The County generated 601,862 tons of commercial waste;

Wood pallets were estimated to comprise 2.6 percent of the commercial waste stream, totaling 15,869 tons;

Untreated wood waste was estimated to comprise 6.5 percent, or 39,169 tons of commercial waste.

While this study was informative for planning purposes, it acknowledges that the absence of field verification of commercial waste composition is a limitation to the methodology used. Given the requirement to accurately and defensibly quantify the generation of wood pallets resulting from the pallet ban, it was necessary to perform more detailed analysis of these materials.

2.2. DATABASE OF COMMERCIAL BUSINESSES

At the outset of this project, Mecklenburg County had acquired an updated database of commercial businesses from InfoUSA, the same third party data provider that supplied the underlying data for the County’s Commercial Waste Characterization Study (as described above). The MSW Team relied on this database (2007 Database) to guide several of the

1 “Mecklenburg County Commercial Waste Characterization Study,” R. W. Beck, January 2006. 2 The InfoUSA database used in the Commercial Waste Characterization Study was provided by the Charlotte Chamber of Commerce. A more recent database from InfoUSA was provided by Mecklenburg County for this study, and will be discussed later.



research elements of this project. This section describes the contents of the InfoUSA database made available to the MSW Team for use in this project.

According to the 2007 InfoUSA database, there are 41,879 total businesses in the County. This figure in itself is of interest when compared to the 33,455 establishments contained in the InfoUSA database used for the Commercial Waste Characterization Study (2005 Database). Further, the 2007 Database reflected 585,986 employees compared to the 534,858 in the 2005 Database. In summary, there were 25 percent more commercial establishments in the 2007 Database compared to the 2005 Database, but only 9.5 percent more employees. While it was beyond the scope of this study to research the differences between the two databases, it appears that either (a) there has been significant growth in small businesses in Mecklenburg County in recent years, or (b) InfoUSA has improved its ability to capture information about these small businesses.

Of particular interest to this study, the InfoUSA database contains the North American Industrial Classification System (NAICS) code for each business. The NAICS code denotes the type of activity performed by each business. Further, the InfoUSA 2007 Database contains other business descriptors that are useful in evaluating the business waste generation and waste management characteristics, including:

Number of Employees (Actual): identifies the number of employees who work at this location or business.

Square Footage Used: estimate of the square footage the location or business occupies.

Work-at-Home (Cottage Code): identifies home businesses.

Table 2-2 summarizes the total number of Mecklenburg County businesses by 2-digit NAICS code. Home businesses were excluded from this table.

Table 2-2 Summary of Mecklenburg County Commercial Businesses NAICS 2-Digit Code

Description Count of Businesses

Total Employees

Total Square Footage (1)

11 Agriculture, Forestry, Fishing and Hunting 90 455 416,250

21 Mining, Quarrying, and Oil and Gas Extraction 37 491 893,750

22 Utilities 31 7,661 806,250

23 Construction 3,890 37,962 25,310,000

31-33 Manufacturing 1,558 42,815 34,301,250

42 Wholesale Trade 2,321 39,092 45,642,500

44-45 Retail Trade 5,588 76,822 53,952,500

48-49 Transportation and Warehousing 966 20,355 18,188,750

51 Information 907 16,131 15,660,000

52 Finance and Insurance 2,668 37,930 16,593,750

53 Real Estate and Rental and Leasing 2,533 19,754 17,390,000

54 Professional, Scientific, and Technical Services 5,254 43,640 29,376,250

55 Management of Companies and Enterprises 33 11,410 818,750

56 Admin / Support / Waste Management 2,041 25,728 13,248,750

61 Educational Services 797 28,106 16,781,250



NAICS 2-Digit Code


Total Employees

Total Square Footage (1)

62 Health Care and Social Assistance 3,214 44,209 25,872,500

71 Arts, Entertainment, and Recreation 637 8,638 7,935,000

72 Accommodation and Food Services 2,375 46,175 16,918,750

81 Other Services (except Public Administration) 4,814 29,297 34,592,500

92 Public Administration 496 21,304 10,637,500

99 Unclassified Establishments 31 734 850,000

NA Not available (2) 1,598 7,277 38,320,000

Total 41,879 565,986 424,506,250 Source: InfoUSA 2007 Database. (1) NAICS identifies each business as having a square footage of 0 to 2,499; 2,500 to 9,999; 10,000

to 39,999; or 40,000 or greater. For purposes of this analysis, MSW Consultants has assumed the midpoint of the each range for businesses identified as having 39,999 square feet or less. For businesses identified has having 40,000 square feet or more, MSW Consultants has assumed the business has 50,000 square feet

(2) Represents the businesses which did not have a NAICS code according to the 2007 Database Although only the 2-digit NAICS codes are shown in the table above, the NAICS code for each business in the County contains a total of five digits. Each successive digit of the NAICS code improves the specification of the type of business. For example:

The 2-digit code for Construction is 23;

The 3-digit code 236 specifies Construction of Buildings

The 4-digit code 2362 is yet another subset: Nonresidential Building Construction

The 5-digit code 23622 is the most specific description, e.g., Commercial and Institutional Building Construction

Specific usage of the InfoUSA 2007 Database is described in later sections of this report.

2.3. WOOD PALLET RESEARCH

As one of the two primary focal points of the study, wood pallets warrant some additional background. This section provides a brief introduction to wood pallets, and also advances several default assumptions about the size, dimensions, and weight of pallets that are used throughout this report.

2.4. PALLET MANUFACTURING

Almost everything manufactured, imported or purchased in the United States has been on a pallet during shipment at some time or another. Wood is the material that is used to construct the vast majority of these pallets. Wood combines strength, abundance as a raw material, and relatively low cost, and is among the easiest materials to manufacture and repair compared to other materials used for pallet construction.3 Broadly speaking, a pallet consists of a platform 3 Plastic lumber, paper, and metal are also used to manufacture pallets.



or series of slats (known as the “deck”) on which payload rests, supported by a frame that enables transport of the pallet by a forklift. Pallets can be defined by a uniform set of characteristics that include:4

Pallet Class: Pallets are classified as either stringer-class or block-class to denote the type of framing that supports the deckboards or panel. Stringers run the length of the pallet and are more sturdy, while blocks simply connect top deck to bottom deck. Stringer-class pallets are the strongest and most commonly used pallet.

Usage Profile: Pallets can be either Multiple Use (M) or Limited Use (L). Multiple use pallets are intended to be used at least 10 times before needing their first repair, and are also known as returnable or special use pallets. Limited use pallets are for an average of up to nine trips, and are also known as shipping or general service pallets. Both multiple and limited use pallets are designed with the assumption that the pallet will be moved five times during one shipment with average handling during each trip.

Pallet Type: Pallets are further classified as being two-way, partial four-way, or four-way to denote the number of sides of the pallet which can be accessed by a forklift for movement of the pallet. Two way entry accepts lift equipment from the front and back of the pallet only. Partial four way entry has equipment entry at both ends and only partial entry on the sides. A full four way entry pallet allows full equipment entry in front, rear, and both sides.

Decks: Pallets can be single or double faced. Single face pallets have slats only on the top, while double face pallets have slats on both the top and the bottom.

Reversibility: Double faced pallets can be reversible if both the top and bottom deck are designed to hold payload. Otherwise a pallet is nonreversible.

Dimensions: The length and width of a pallet are based on the direction of the deckboards. The pallet’s width is measured as the length of the deckboard, while the length is measured as the length of the stringerboards (or top stringerboard for block-class pallets).

Appendix A contains a Pallet Classification reference document that describes pallet characteristics in full detail.

4 Various sources: “Uniform Standard for Wood Pallets,” National Wood Pallet and Container Association, 2005; and Pallet Classification.



In 2004 there were about 450 million new pallets produced in the United States and Canada. About 1.9 billion were in use at any given time5. The 48 x 40 inch pallet is the most common pallet used in the United States. Table 2-3 below shows the 10 most common sizes and the typical industries that use each size.

Table 2-3 Top 10 Pallet Sizes in North America in 2000

Pallet Size (in.) Production Rank Typical Industry

48 x40 1 Grocery, common in many other industries

42 x 42 2 Telecommunications, and Paint

48 x 48 3 Drums

40 x 48 4 DOD, Cement

48 x 42 5 Chemical and Beverage

40 x 40 6 Dairy

48 x 45 7 Automotive

44 x 44 8 Drums and Chemical

36 x 36 9 Beverage

48 x 36 10 Beverage, Shingles, and Package Paper Source: “Pallets 101: Industry Overview and Wood, Plastic, Paper, and Metal Options” by John Clarke,

Technical Sales Director, Grate Pallet, Inc. 2004.

The list totals about 60 percent of the annual pallet manufacturing with the 10th most common size in use for less than two percent of the market. The remaining 40 percent of the pallets manufactured are specific to shipping customer needs.

Because waste generation and disposal is measured in terms of weight (tons), the MSW Team attempted to research the average weight of a pallet for use in conversion from pallet counts to weight. There are a number of sources that provide weight data about pallets. The weight of a typical 48 x 40 x 5 inch stringer partial four-way multiple use pallet from the manufacture – the most common pallet – is about 59 pounds.6 However, the weights of a pallet depends on many factors, including pallet dimensions; class; usage, and style; species of wood (or other material) used in construction; and the moisture content (MC) of the wood. It is of particular interest that the weight of a pallet varies significantly over the life of the pallet depending on the moisture content.

5 “Pallets 101: Industry Overview and Wood, Plastic, Paper, and Metal Options” by John Clarke, Technical Sales Director, Grate Pallet, Inc. 2004. 6 “Pallet Design System Version 4.0 Pallet Physical Proper Analysis” National Wooden Pallet and Container Association (NWPCA) in cooperation with: Pallet and Container Research Laboratory, Virginia Tech Department of Wood Science and Forest Products; USDA Forest Service and Forest Products Laboratory; APA – The engineered Wood Association; Software Technologies Laboratory, Virginia Tech Department of Industrial and Systems Engineering 2006.



Table 2-4 below shows the average weight of a medium duty stringer pallet as described above.

Table 2-4 Average Weight of Medium Duty 48 x 40 Pallets

Moisture Content (MC) Weight (lbs)

At Manufacture 59

25% MC 41

19% MC 39

15% MC 38

12% MC 37

As shown in the table, the weight of a pallet declines significantly from manufacture (assuming green wood). For this study, MSW Consultants reviewed prior published data about pallet weight, and also consulted with pallet researchers at the U.S. Forest Service’s Southern Research Station (SRS), who are in the process of completing a survey conducted in 2006 about the pallet recycling industry. Based on these sources of information, we have used 50 pounds as a reasonable estimate for the weight of a pallet in Mecklenburg County at the current time.

2.5. PALLET RECYCLING

The SRS is a leading expert on pallet recycling. SRS pallet research dates back to the early 1990s, with updates issued sporadically as funding is available. The SRS released its most recent comprehensive survey of pallet manufacturing and recycling in 1999, and is currently finalizing another update. However, at this time the 1999 data is the most recent that is available.

Based on extrapolations from the 1999 SRS study, various sources mention that between 400 and 500 million new pallets were manufactured annually in the U.S. during the 2001 to 2002 timeframe. More recent data was not found. In 1999, 300 million of these pallets were being captured for recycling and reuse. Once pallets reached the recycler, the vast majority were beneficially used. Most pallets are reused either as-is or after some repair (or re-use of parts). Unusable pallet parts are most often ground, and only a very small percentage are landfilled. These breakdowns are shown in Figure 2-1.



Figure 2-1 Disposition of Recycled Pallets, 1999

Source: “Recovery, Reuse and Recycling by the United States Wood Packaging Industry: 1993 to 2006,” by Robert Bush, Philip Araman, and E. Brad Hager.

2.6. MATERIAL DENSITIES

Throughout the research and analysis performed in this study, MSW Team members relied on volumetric estimates to collect data in the field. Volume-based estimates were used for (a) vehicle compartments, (b) commercial container sizes, (c) and the volume of targeted materials within a load or loose. Volumetric estimates are the only reasonable way to gather much data in the solid waste and recycling industry, simply because the amount, in-situ conditions, and characteristics of waste and recyclables (especially wood pallets and clean wood) prevents the use of scales to obtain defensible weights.



It was therefore necessary throughout our analysis to be able to reasonably convert from volume to weight-based measurements. Table 2-5 below shows the density conversion and other related factors that were used to estimate the quantity of targeted materials throughout this analysis.

Table 2-5 Survey Data Units and Conversion Factors

Material Conversion Factors

Wood Pallets

50 lbs per pallet 5.5 pallets per cubic yard (CY)

Clean Wood Loose: 300 lbs/CY

Old Corrugated Cardboard (OCC)

Loose: 50 lbs/CY Flattened: 150 lbs/CY Bales: 600 lbs each Baled odd size: 1,000 lbs/CY Compacted: 400 lbs/CY

Film Plastic Loose: 30 lbs/CY 1 CY in compactor = 4 CY loose 1 pallet’s worth of wrap = 1/6 loose CY

2.7. C&D WASTE COMPOSITION

One of the objectives of this study was to defensibly estimate the quantity of wood pallets, clean wood, and other targeted materials being disposed in the C&D waste stream. To accomplish this objective, the MSW Team performed a full characterization study of Mecklenburg County’s C&D waste stream. This study involved visual surveying of incoming loads of C&D debris at two in-county facilities (Mecklenburg County’s Foxhole Landfill and the North Mecklenburg C&D Landfill) that together receive approximately 80 percent of the C&D debris reported to be disposed from Mecklenburg County.



A separate report was developed to present the full results of this county-wide C&D waste characterization study7 (C&D Composition Study). However, pertinent results of the C&D Composition Study are shown in Table 2-6 below.

Table 2-6 Targeted Materials Disposed in C&D Waste Stream

90% Conf. Interval

Targeted Material Categories Mean Standard Deviation Lower Upper

Annual Quantity

Plastic Film 0.3% 0.1% 0.2% 0.4% 1,281 Vinyl Siding 0.1% 0.0% 0.0% 0.1% 194 Pallets 2.1% 0.3% 1.6% 2.5% 7,752 Crates 0.5% 0.3% 0.0% 0.9% 1,853 Untreated Wood 16.5% 1.4% 14.1% 18.8% 62,145 Drywall - Unpainted 6.8% 1.1% 5.0% 8.7% 25,762 Asphalt Roofing 6.4% 1.2% 4.4% 8.4% 24,043

Total – Targeted Materials 32.7% 123,030

Non-Targeted C&D Debris 67.3% 254,090 Source: Mecklenburg County C&D Debris Composition Study, 2008

As shown above, the targeted materials make up almost 33 percent of the total C&D waste stream, with untreated wood waste accounting for almost half of the total. A complete summary of the methodology that derived these results can be found in the C&D Composition Study.

7 “Mecklenburg County Construction & Demolition Debris Composition Study,” May 2008.


3. METHODOLOGY

3.1. INTRODUCTION Because of the scope and complexity of the market for generating, collection, and processing or disposing of pallet and clean wood waste, the project methodology contained a number of complimentary tasks aimed at deriving defensible findings. This section describes the approach that was ultimately developed to comprehensively research the generation, recovery and disposal of wood pallets, clean wood, and the other materials targeted in the study. Generally, separate approaches were pursued for the commercial sector and the construction and demolition (C&D) sectors. Specific steps of the project approach for each generator sector are described below.

3.2. COMMERCIAL GENERATOR SECTOR APPROACH As described in Section 2 of this report, the commercial sector has been defined in this study as every non-home-based business other than businesses classified as NAICS code 23 (Construction). Almost 42,000 such entities exist in Mecklenburg County. Because of the diversity of the commercial sector – in terms of both business function and size – the MSW Team used multiple strategies to gather information about pallet and clean wood generation. Our approach for researching the commercial sector encompassed the following efforts:

Hauler surveys to inquire about the incidence of pallet and clean wood generators, alternative disposal options, and procedures for collecting pallets from commercial accounts;

Visual observations of commercial waste deliveries to local disposal facilities to estimate the breadth of pallet and clean wood disposal;

Commercial business on-site research included extensive on-site observations and interviews of businesses identified as being likely pallet generators; and

Telephone surveys of a representative cross section of County businesses.

Specific research performed for the commercial sector are described below.

3.2.1 HAULER SURVEYS At the time of the study, there were a total of seven permitted haulers1 that were collecting commercial waste in Mecklenburg County. It was not known how many of these haulers were aware of the impending pallet ban, which could potentially impact their ability to accept wood pallets from their small business customers for disposal if the ban were to be enforced. It further was hypothesized that these haulers would potentially be able to provide insight into the generation, collection, and recycling/disposal of wood pallets and clean wood, and that some of the haulers may even be providing collection service for these source separated items. However, it was also acknowledged that private haulers may not be willing to respond to a

1 Another 11 haulers were reported to only collect residential wastes, and 10 haulers collect only C&D debris.

3. METHODOLOGY


direct survey, for a variety of reasons including concern about the confidentiality of their business and a lack of time to respond.

In an attempt to capture some insight from the commercial haulers doing business in the commercial (and C&D) sectors, the MSW Team conducted a brief survey of all seven commercial waste haulers (as well as the C&D haulers). The MSW Team developed a cover letter and survey instrument to guide the responses, and contacted haulers by phone and e-mail to request participation. Five of the seven commercial waste haulers provided at least some feedback from the survey, with the other two commercial haulers not responding to our inquiries or else declining to participate. Appendix B contains the survey instrument and a matrix of survey responses.

3.2.2 QCTS SURVEY OF COMMERCIAL VEHICLES Mecklenburg County’s commercial waste is delivered primarily to one of two facilities: the BFI-Speedway Landfill just across the border in Cabarrus County, and the Queen City Transfer Station (QCTS), owned by Republic Services, in Charlotte. BFI-Speedway is estimated to receive almost 70 percent of all Mecklenburg County waste (residential, commercial and C&D), while QCTS receives approximately 16 percent of all waste (which is predominantly commercial). Commercial waste is also being hauled to several other landfills and transfer stations in surrounding counties and in South Carolina.

It is the opinion of the MSW Team that a full commercial waste stream characterization study, including field sampling and physical sorting of a representative sample of incoming commercial waste loads, is the preferred method for documenting the quantity of wood pallets, untreated wood waste, and other targeted materials being disposed in the County’s commercial waste stream. Prior to the outset of this project, MSW Consultants approached facility management at both BFI-Speedway and QCTS to request access to each site for the purpose of performing physical sampling and sorting of commercial wastes.

Access was denied by BFI-Speedway, which limits any ability to conduct a representative physical characterization study of commercial wastes given the large proportion of Mecklenburg County commercial waste received at that facility.

Limited access was, however, granted at the QCTS. Because of space limitations at this transfer station, it was not possible to conduct physical sampling and sorting of incoming commercial waste. Because the study was primarily targeting wood pallets and untreated wood waste, the MSW Team opted to perform a visual survey of incoming commercial waste loads to identify the incidence of wood pallets and untreated wood.

The MSW team conducted visual observations of incoming loads on August 7 and 8, 2007, from 7:00 A.M. until 3:00 P.M. The facility (which is open from 6:00 AM to 6:00 PM) received a total of 411 incoming vehicles over these two days, of which we made detailed visual observations of 147 (36 percent). An “nth truck” selection process was applied, and it is noteworthy that a significant number of incoming loads contained pure C&D debris as well as commercial waste. The MSW field supervisor recorded the following information about each load based on visual observation:

The vehicle type of the incoming load (frontload vehicle, roll-off compactor box, roll-off open top box) and the size of the container (in cubic yards);

A qualitative assessment of the type of waste;

3. METHODOLOGY


The percentage fullness of the tipped load relative to the size of the truck or box that delivered the load (e.g., 75 percent full);

A count of the number of pallets and crates that were visible within the load, as well as an estimate of the percentage of the load containing pallets/crates. For purposes of converting to weight pallets were assumed to weigh 50 pounds each;

An estimate of the percentage of the load containing untreated wood waste. For purposes of analysis, clean wood was assumed to have a density of 309 pounds per cubic yard.

The hauler and truck number were also recorded for each load to allow, at the end of the day, weigh tickets for each observed load to be obtained from the facility scalehouse. Hauler-related data was not preserved at the request of QCTS management.

Although the methodology for performing the visual observations of commercial waste loads was consistently applied, and the MSW Team believes the data provided by this exercise is meaningful, it should be noted that visual surveying was limited by three factors.

Limited Space: Because of the space limitations, it was not possible to walk around tipped loads to clearly observe all sides of the load. Although the QCTS entry bays are open and the tipping floor is well lit, the MSW Team field supervisor for this effort was required to remain outside the unloading bays and could not approach the tipped loads. It was therefore only possible to observe three sides of the tipped load – both sides could be observed, as well as the “front” of the load (i.e., the portion of the tipped load closest to the cab). To the extent wood pallets or clean wood was contained in the rear of a tipped load (i.e., the portion of the load at the back of the truck), the MSW field supervisor may not have been able to clearly observe these items.

No Spreading of Loads: In a related matter, because of the space limitation and high traffic volume, it was not possible to spread out the tipped loads to improve the ability of the field supervisor to observe the interior contents of the loads. Such spreading has been shown to improve the accuracy of visual characterization (and was performed in the full C&D characterization study).

Driver Interviews Prohibited: At the request of QCTS facility management, the MSW field supervisor was not permitted to talk to the drivers of incoming vehicles. This requirement is understandable and was intended to minimize the impact of this study on QCTS’s customers.

In analyzing the results, the MSW Team has applied its professional opinion to identify the sources of incoming loads of waste at the QCTS, and to estimate the quantity of wood pallets and untreated wood waste. However, given the limitations described above, we cannot be certain that our results achieve a degree of accuracy that would be possible if no such limitations existed.

The raw data obtained from this analysis is contained in Appendix C.

3.2.3 COMMERCIAL GENERATOR RESEARCH AND SURVEYING Because of the limitations to commercial sampling, visual surveying, and sorting, the MSW Team devoted extensive resources to direct surveying of businesses to research wood pallet and untreated wood waste generation, disposal, and recycling. Data on corrugated cardboard

3. METHODOLOGY


and recyclable plastic films were also obtained at those businesses targeted for surveying. This section describes the research undertaken as well as the findings.

As described previously, the InfoUSA database of Mecklenburg County businesses contained almost 42,000 businesses in the County. This database was used as a starting point for classifying businesses for follow-up research.

There are over 700 5-digit NAICS codes that describe the exact nature of a business. The MSW Team reviewed the 5-digit NAICS codes and the business data contained in the InfoUSA database in detail. Based on this analysis, the following logical steps were applied to subdivide the InfoUSA database into meaningful groupings. The intended result was a reasonable strategy to obtain representative coverage of all Mecklenburg County businesses through a combination of phone surveys and on-site research, while focusing the majority of our efforts on those businesses that are most likely to generate wood pallets and/or clean wood.

The MSW Team undertook the following steps to identify pallet/wood generators:

Excluded 1,598 of businesses that contained no NAICS code. This represents approximately 3.8 percent of all businesses in the database. For the sake of simplicity, we will assume that the results we obtain for the remainder of the database will apply to these unspecified companies. Although this assumption may not be entirely valid, the relatively small fraction of unspecified businesses does not warrant more rigorous treatment, in our professional opinion.

Excluded 35 of businesses identified as NAICS code 99, unclassified establishments.

Excluded 3,757 of home-based businesses.

Businesses in the Construction industry (NAICS code 23) were excluded. Pallet and wood generation in the construction and demolition industry were researched through a full C&D waste characterization analysis performed in conjunction with this project.

The 5-digit NAICS codes were reviewed in detail and a determination was made as to the likelihood that those businesses would generate pallets and/or clean wood. A total of 243 5-digit NAICS codes (33 percent of the total) were identified as industries that would be likely to generate pallets and/or clean wood.

As a final step, we considered the employment and square footage of the businesses that are likely to generate pallets and/or clean wood. It was reasoned that a very small business (i.e., one with few employees and low square footage of their building) would not be likely to generate pallets and/or clean wood in any significant volume. For the purposes of completing the analysis of the InfoUSA database, we established a threshold of five or fewer employees with less than 2,499 total square footage.

Table 3-1 summarizes the number, employment, and square footage of the businesses in Mecklenburg County that remained in the database after application of the filtering rules described above. A detailed accounting of these businesses is provided in Appendix D. Note that although many of the larger businesses/high pallet generators are likely to have pallet recycling programs in place, there was still a need to survey these firms because it is likely that the recovery rate would not be 100 percent, and therefore these large businesses could be both large recyclers and large disposers of pallets.

3. METHODOLOGY


Table 3-1 Mecklenburg County Businesses Likely to Generate Pallets/Wood

NAICS 2-

Digit Code


Total Employees

Total Square

Footage [1]


31-33 Manufacturing 1,268 34,951 28,142,500

42 Wholesale Trade 2,083 29,769 41,758,750

44 Retail Trade 1,384 27,088 18,426,250


56 Administrative and Support and Waste Management and Remediation Services

55 5,334 431,250

62 Health Care and Social Assistance 282 13,678 6,900,000


Total 5,702 130,534 110,563,750

Source: InfoUSA [1] InfoUSA identifies a range of square footage for each business (i.e., it does not specify the

exact square footage) The ranges shown in the InfoUSA database are: 0 to 2,499 square feet; 2,500 to 9,999 square feet; 10,000 to 39,999 square feet; or 40,000 square feet and above. To estimate the total square footage attributable to businesses in each NAICS code, MSW Consultants used the midpoint of each range (and a value of 50,000 square feet was assumed for businesses whose square footage exceeded 40,000).

As shown in the table above, there were 5,702 businesses (roughly 14 percent of the total), with employment of 130,534 (roughly 24% of total) and total square footage of 110,563,750 (roughly 24% of total) that were believed to be the most likely generators of pallets and clean wood. These businesses were concentrated in the manufacturing and the wholesale and retail industries, although some businesses were identified in transportation/warehousing, health care, and other industries.

3. METHODOLOGY


Conversely, there remained in the database a large number of businesses that were deemed less likely to generate pallets/clean wood. MSW Consultants applied a similar test based on size of the business to eliminate business that had 5 or fewer employees and less than 2,499 square feet. Table 3-2 summarizes the 18,857 businesses (roughly 45% of total businesses) in the County that passed the screening for size and square footage that possibly generate wood pallets and/or clean wood, but are in industries that are not believed to generate a significant number of pallets. A summary of the below businesses by NAICS 5-digit code is provided in Appendix D.

Table 3-2 Mecklenburg County Businesses that Possibly Generate Pallets/Wood

NAICS 2-

Digit Code


Total Employees

Total Square

Footage [1]


21 Mining, Quarrying, and Oil and Gas Extraction 37 491 893,750

22 Utilities 31 7,661 806,250

33 Manufacturing 218 7,648 6,068,750

42 Wholesale Trade 176 9,145 3,806,250

44-45 Retail Trade 2,742 46,397 33,698,750


51 Information 896 16,105 15,646,250

52 Finance and Insurance 1,826 35,751 15,541,250


54 Professional, Scientific, and Technical Services

2,661 37,706 26,135,000

55 Management of Companies and Enterprises 33 11,410 818,750


1,184 18,413 11,815,000

61 Educational Services 631 27,823 16,573,750



72 Accommodation and Food Services 1,849 44,539 16,261,250


92 Public Administration 496 21,304 10,637,500

Total 18,857 359,781 234,711,250



As shown, the “Possible Generator” businesses span virtually all industry groups.

3. METHODOLOGY


Table 3-3 below, summarizes the 13,430 businesses that were not researched further, due primarily to their being (a) too small to generate significant quantities of pallets/wood; (b) in industries that do not generate these materials; or (c) were unclassifiable. Appendix D provides a detailed summary of businesses in Table 3-3.

Table 3-3 Mecklenburg County Businesses not Surveyed

NAICS 2-

Digit Code


Total Employees

Total Square Footage

[2] 11 Agriculture, Forestry, Fishing and Hunting 58 112 72,500

21 Mining, Quarrying, and Oil and Gas Extraction 0 0 0

22 Utilities 0 0 0

31-33 Manufacturing 72 216 90,000

42 Wholesale Trade 62 178 77,500

44-45 Retail Trade 1,462 3,337 1,827,500

48-49 Transportation and Warehousing 119 263 148,750

51 Information 11 26 13,750

52 Finance and Insurance 842 2,179 1,052,500


54 Professional, Scientific, and Technical Services 2,593 5,934 3,241,250

55 Management of Companies and Enterprises 0 0 0


802 1,981 1,002,500

61 Educational Services 166 283 207,500


71 Arts, Entertainment, and Recreation 152 233 190,000

72 Accommodation and Food Services 526 1,636 657,500


92 Public Administration 0 0 0

99 Unclassified Establishments 31 734 850,000

NA Not available [3] 1,598 7,277 38,320,000

Total 13,430 37,709 53,921,250



In conclusion, out of the 41,879 businesses in the County, the screening process used in this study identified:

3. METHODOLOGY


Likely Generators: 5,702 businesses, employing 24 percent of county employees, that appeared likely to generate pallets and clean wood;

Possible Generators: 18,857 businesses, employing 64 percent of county employees, that were not believed to be significant generators of pallets and clean wood, but that were arguably large enough to generate these materials in small quantities; and

Non-Generators: 13,430 businesses, employing seven percent of county employees, that were both too small (in terms of employment and square footage) and also in industries that are not known for generating pallets and/or clean wood waste, such as professional offices and small retail establishments.

Figures 3-1 and 3-2 show the breakdown of the number of Mecklenburg County businesses and employment, respectively, in each of the above categories.

Figure 3-1 Expected Pallet/Clean Wood Generation by Industry (No. of Businesses)

0 1,000 2,000 3,000 4,000 5,000 6,000

Agriculture, Forestry, Fishing and Hunting

Mining, Quarrying, and Oil and Gas Extraction

Utilities

Manufacturing

Wholesale Trade

Retail Trade

Transportation and Warehousing

Information

Finance and Insurance

Real Estate and Rental and Leasing

Professional, Scientific, and Technical Services

Management of Companies and Enterprises

Administrative / Support / Waste Management

Educational Services

Health Care and Social Assistance

Arts, Entertainment, and Recreation

Accommodation and Food Services

Other Services (except Public Administration)

Public Administration

Unclassified Establishments

Not available [3]

Number of BusinessesLikely Pallet/Wood Generators Possible Pallet/Wood GeneratorsUnlikely Pallet/Wood Generators

3. METHODOLOGY


Figure 3-2 Expected Pallet/Clean Wood Generation by Industry (Employment)

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000

Agriculture, Forestry, Fishing and Hunting

Mining, Quarrying, and Oil and Gas Extraction

Utilities

Manufacturing

Wholesale Trade

Retail Trade

Transportation and Warehousing

Information

Finance and Insurance

Real Estate and Rental and Leasing

Professional, Scientific, and Technical Services

Management of Companies and Enterprises

Administrative / Support / Waste Management

Educational Services

Health Care and Social Assistance

Arts, Entertainment, and Recreation

Accommodation and Food Services

Other Services (except Public Administration)

Public Administration

Unclassified Establishments

Not available [3]

EmploymentLikely Pallet/Wood Generators Possible Pallet/Wood GeneratorsUnlikely Pallet/Wood Generators

As shown in the Figure above, when measured by employment, the Likely and Possible generator strata are shown to comprise the majority of Mecklenburg County, and this is where our commercial sector research was focused. In summary, our direct research encompassed over 90 percent of the County’s non-construction employment base.

The MSW Team used a combination of telephone surveying, on-site research, and visual analysis of commercial waste loads to investigate pallet and clean wood generation, disposal, and recycling among the subsets of Mecklenburg County businesses. Table 3-4 identifies the research strategies used to further investigate each sector.

Table 3-4 Research Methods for Commercial Sub-Sectors

Subsector Number of Businesses

On-site Research

Observation of Targeted

Loads

Phone Surveying

Likely Generators 5,702 Yes Yes Yes

Possible Generators 18,857 No No Yes

Non-Generators 13,430 No No No

3. METHODOLOGY


The universe of Likely Generator and Possible Generator businesses subject to random sampling for telephone and/or on-site surveys totaled 24,559 businesses, or 59 percent of total businesses, representing 88 percent of total employment. A discussion of the phone survey, on-site research, and targeted commercial load research methodology is presented below.

3.2.4 TELEPHONE SURVEYS The MSW Team believes that the most effective, accurate, and meaningful way to gather information about waste management and recycling behaviors of commercial businesses is through on-site observation and research, combined with interviews with business operational personnel. However, given the size and diversity of the universe of businesses in Mecklenburg County, it was beyond available resources to complete this project strictly through on-site research.

Telephone surveys, while less in depth, provide a way to contact many more businesses to collect basic information about waste management and recycling practices. In an attempt to balance the need for in-depth research with available budgeted resources, the MSW Team completed telephone surveys of 526 Mecklenburg County businesses to inquire about their generation of wood pallets, clean wood, OCC, and film plastics. Businesses were selected from the InfoUSA database, as described above.

The majority of the telephone surveys – 365 commercial businesses – targeted the commercial establishments believed to be Possible pallet/clean wood generators. This allowed the Project Team to concentrate our on-site research on the businesses most likely to generate pallets, and therefore most likely to be impacted by a landfill ban on pallets.

The result was that the Project Team relied on telephone surveys to develop estimates of the generation and disposition of targeted materials for Possible generators, and concentrated our on-site research and analysis on Likely generators. Telephone surveys of 161 Likely generators were also conducted to expand the universe of Likely generators surveyed. Although onsite research was the primary means of data collection for the Likely generators, the telephone surveys were intended to supplement on-site research and enable some comparison between the accuracy and completeness of telephone survey data relative to on-site research.

To perform the telephone survey, the MSW Team randomly selected 1,000 “likely” businesses and 3,000 “possible” businesses. Phone surveyors began contacting companies sequentially, making up to three attempts to reach the appropriate person at each business contacted. Incorrect or disconnected phone numbers, as well as businesses that were unresponsive after three attempts, were not surveyed. Surveyors proceeded through the randomly selected list of businesses until sampling targets were achieved. Table 3-5 summarizes the phone surveys, and a copy of the telephone survey instrument is attached in Appendix B.

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Table 3-5 Summary of Commercial Generator Phone Surveys

“Likely” Generators “Possible” Generators

Number of Businesses in Universe 5,702 18,857

Randomly Selected Businesses 1,000 [1] 3,000 [1]

Responses (Response Rate) 161 (16%) 365 (12%) [1] Surveyors progressed through their randomly selected list of companies until reaching

prescribed response targets. Not every business was contacted.

At the outset of this task, the telephone surveys of the Likely generators were intended to be used as a mechanism to contact businesses who would be targets for further on-site research to be conducted at a later stage of the project. However, given the logistical challenges associated with mapping out and visiting Likely generators for on-site research, phone surveys were ultimately performed strictly to supplement the on-site research.

Survey responses were compiled by 2-digit NAICS code. For each 2-digit NAICS code, the MSW Team calculated the total number of businesses surveyed, as well as the employment represented by those businesses. Further, generation rates were calculated for each 2-digit NAICS code.

Table 3-5 summarizes the number of responses received by 2-digit NAICS code for both the Likely and the Possible generators.

3.2.5 ON-SITE SURVEYS The MSW Team believed that on-site observations at business establishments, coupled with interviews of business personnel, would provide the best characterization of wood pallet and clean wood generation and management practices. For this reason, extensive business on-site observations were performed by experienced recycling professionals.

In preparation for on-site generator surveys, the MSW Team (lead by DSM Environmental Services) sorted the list of Likely Generators by zip code and street address. Once on the ground in Mecklenburg County, the MSW Team chose geographic regions of high commercial and industrial activity to survey each day, with the goal of surveying Likely Generators in each broad NAICS category, as well as generators geographically dispersed throughout the County (in the event that behavior varied geographically as well as by size and NAICS code).

Ultimately, the MSW Team conducted on-site generator observations during two separate one-week field data collection events that took place in November and December 2007. During each week, two to three MSW Team members (lead by DSM professional staff) canvassed the County to collect data.

The MSW Team walked into businesses that were either on the Likely Generator list, or had pallets visible on their premises. The MSW Team introduced the purpose of the survey and attempted to speak face to face with the employee/business manager most likely to know about pallet generation and disposal. Visual inspections of storage areas and dumpsters were sought and, in most cases, performed at those sites that agreed to the survey.

To assure consistency of data collection, the same survey instrument as was used in the phone survey was used as a starting point for on-site observations and interviews (see Appendix B).

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However, the face-to-face dialog, as well as the opportunity to visually confirm or further explore certain responses, provided the field interview team with the ability to ask further clarification questions in response to what was observed at the site.

In each case, the MSW Team worked with the company’s representative to establish estimates of generation and how each material was managed. Often this involved a series of questions about generation, recycling and disposal for each material, with prompts from DSM as appropriate to assist the company representative with estimating generation.

Over the course of two separate extended field visits, a total of 281 businesses were included in the on-site observations and interviews. Table 3-6 summarizes the distribution of businesses by 2-digit NAICS code captured in the on-site generator surveys.

Table 3-6 Summary of Phone and On-site Survey Responses

NAICS 2-

Digit Code

Description Number of Responses

from Likely

Generators

Number of Responses

from Possible

Generators

On-site Survey

Responses

11 Agriculture, Forestry, Fishing and Hunting 0 0 1 21 Mining, Quarrying, and Oil and Gas Extraction NA 1 NA 22 Utilities NA 2 NA 31-33 Manufacturing 31 5 55 42 Wholesale Trade 62 3 95 44-45 Retail Trade 42 71 82 48-49 Transportation and Warehousing 17 3 21 51 Information NA 17 NA 52 Finance and Insurance NA 36 NA 53 Real Estate and Rental and Leasing NA 35 NA 54 Professional, Scientific, and Technical

Services NA 52 3 [1]

55 Management of Companies and Enterprises NA 1 NA 56 Administrative and Support and Waste

Management and Remediation Services 3 25 3

61 Educational Services NA 7 NA 62 Health Care and Social Assistance 3 24 8 71 Arts, Entertainment, and Recreation 3 6 3 72 Accommodation and Food Services NA 41 NA 81 Other Services (except Public Administration) NA 36 3 [1]

Total 161 365 281 [1] These NAICS codes were not initially targeted in the on-site surveys; rather, these

establishments were observed to have pallets awaiting recycling or disposal and were added to the list of on-site surveys while the field study was in progress.

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In total, 807 Mecklenburg County businesses were surveyed either by phone or on-site in the performance of this project. These businesses were contacted in proportion to the distribution of business types as defined by the NAICS code system.

3.2.6 INFOUSA DATABASE ACCURACY As described in Section 2, research into the universe of commercial businesses in Mecklenburg County necessarily relied on an underlying database of businesses. A database of businesses generated by InfoUSA was used for this purpose. It should be noted that any database of businesses would be expected to contain errors and inaccuracies simply because of the challenges associated with maintaining real-time data for such a large population. Although it was beyond the scope of this study to analyze the reason for InfoUSA inaccuracies, we can reasonably hypothesize that errors arise because of the time lag between new business registrations or closures; acquisition of one business by another; integration of records from multiple underlying sources; and human error.

Prior to surveying, the MSW Team reviewed the InfoUSA database to identify potential shortfalls in the data. This review identified the following:

Missing Business Addresses: A critical part of performing field observations, is to be able to have the addresses for the commercial generators. There were 2,489 businesses (6.0% of the total businesses in InfoUSA) that had neither a primary nor a secondary address in the database and therefore could not be targeted for field survey (or otherwise verified).

Duplicate Listings: In evaluating the entire InfoUSA database, the MSW Team found only 223 businesses (0.5%) with the identical business name and primary address, which suggests that these may be duplicates. For example, Bi-Lo Grocery Stores appears twice in the InfoUSA database with an identical address (9815 Rose Commons Drive), NAICS, employee counts, and square footage – this is likely a duplicate entry. However, the degree of duplication of records is harder to discern for another fraction of businesses in the database. This was the case where there was a relatively large building (or buildings) with multiple commercial services being provided. For example, Rooms To Go Clearance and Rooms To Go Warehouse are both located at 2730 South Interstate Service Road (abbreviated differently in the InfoUSA Database) with identical NAICS. However, InfoUSA reports different employee counts and square footage for Rooms To Go Clearance and Rooms To Go Warehouse, so this may reflect two separate divisions of a business with the same mailing address. Our review of the database suggests that between two and four percent of listings may be full or partial duplicate listings.

PO Box for Both the Primary Address and Secondary Address: A PO Box as a primary address and secondary address prevented a businesses from being selected for field observation. Only 315 businesses were found to have only a PO Box address as both a primary address and a secondary address or a PO Box address as a primary address and no secondary address. The use of PO boxes did not appear to be a significant problem.

The MSW Team attempted to evaluate the accuracy of the InfoUSA database during both the phone and on-site surveys. During the phone survey, an effort was made to validate the employment and square footage data contained in the database. On average, the self-reported employment by survey respondents was between five and 11 percent less than the employment reported in the InfoUSA database. This may be attributable to the fact that the

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survey sought to capture the number of full-time equivalent (FTE) employees, while the InfoUSA database may have reported total employees. Although the MSW Team at first attempted to also validate the square footage and the NAICS code reported in the InfoUSA database, survey respondents were predominately unable to confirm these items.

Accuracy of the InfoUSA data was also validated during on-site surveys. Of the 281 surveyed locations, all but seven businesses surveyed by the MSW Team were ultimately found in the InfoUSA database, which suggests that the database is reasonably complete. However, inaccuracies in the employment and square footage data in the InfoUSA database caused some businesses to be misclassified during the screening process for Likely and Possible Generators. During field surveys, the MSW Team noted:

Inaccuracy in Employment Information: Of the businesses for which employment was confirmed with the local representative, 65 percent reported a number of employees that varied by 15 percent above or below the count of employees specified in the InfoUSA database, with 19 percent reporting employment that varied by 50 percent or more. Total employment in the InfoUSA database seems reasonable at the macro level based on other comparable data sources, but inaccuracies clearly exist throughout individual company listings.

Inaccuracy of Square Footage: Approximately 50 percent of businesses surveyed in site reported a square footage that fell outside the Info USA database square footage range assigned to the business.

It was beyond the scope of this study to investigate the discrepancies in the InfoUSA database. Because total employment seems the most reasonable in the database, and because the MSW Team has no basis for validating the total square footage in the InfoUSA database, for the remainder of this study we have relied on employment as a better basis for extrapolating results.

3.2.7 TARGETED COMMERCIAL LOAD OBSERVATION For the most part, on-site surveys provided the best glimpse into the disposed waste stream at a wide range of businesses, and MSW Team members were able to both interview business personnel and visually observe the contents of material streams targeted for both disposal and recycling/reuse. Most commercial businesses use dumpsters as their primary container for refuse, and it was possible to open and visually scan the contents of dumpsters during the on-site surveys.

However, some of the larger establishments utilize roll-off compactor boxes for refuse. These boxes can be as large as 30 yards, and are entirely enclosed except for the in-feed chute. Compactor boxes are prevalent at establishments like big box stores, grocery stores, and certain manufacturers, all of which are believed to generate wood pallets as well as other targeted materials. As a consequence of these containers being enclosed, it was not possible for on-site surveyors to view the contents of the disposed waste stream at these establishments to evaluate pallet, clean wood, cardboard and plastic film generation.

To determine how best to target compactor box loads for further visual observation, the MSW Team reviewed the distribution of responses to the on-site surveys compared to the overall distribution of establishments in the County. Table 3-7 compares the on-site surveys completed against the percent of establishments in the Likely Generator categories based on the InfoUSA database. The table shows the relative percentage of each 2-digit NAICS in the

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on-site surveys versus that found in the entire universe of Likely Generators. While these allocations tracked reasonably well, the manufacturing, transportation, and health care sectors were found to be slightly under-represented, and were subsequently targeted for further observation.

Table 3-7 Comparison of On-site Surveys and Total Likely Generator Businesses in Mecklenburg County

On-site Surveys Generator Types

Number of On-site Surveys

% of Total On-site Surveys

% of Total Likely

Generator Businesses [1]

Wholesale 95 35.7% 36.5%

Retail 82 30.8% 24.4%

Manufacturing 55 20.7% 22.3%

Transportation 21 7.9% 9.4%

Healthcare 6 2.3% 4.9%

Arts 3 1.1% 1.4%

Admin 3 1.1% 1.0%

Agriculture 1 0.4% 0.1%

Total 266 100.0% 100.0%

[1] Source: InfoUSA

Ultimately, the MSW Team did not attempt to make arrangements with healthcare entities due to the potential sensitivity among Foxhole Landfill neighboring communities to having these wastes tipped at the facility. Rather, some additional “big box” retailers (such as Wal-Mart and Sears) were added to supplement our on-site survey data.

The MSW Team made arrangements with local haulers to acquire and deliver compactor box loads to the Foxhole Landfill, where they could be tipped and visually surveyed. In preparation for the visual sampling of these targeted commercial loads, the MSW Team contacted county permitted haulers to recruit delivery of these loads. The County offered to waive the tip fee as an incentive. Local haulers Republic Waste, Hawk Sanitation, Allied Waste, and All-Points Waste ultimately cooperated in delivering compactor box loads from targeted Mecklenburg County establishments. From February 4th through 7th, 2008, an MSW Team member was on-site at Foxhole Landfill to receive, confirm, and visually survey the incoming loads.

Haulers were asked to provide the name, address, type of business, and the frequency of pulls from each establishment. MSW Team members spoke directly with dispatch to line up appropriate loads. The on-site MSW Team visual surveyor photographed and logged each incoming vehicle onto a field sample sheet. Drivers of these trucks were instructed to announce to the scale attendant (fee collector) that he/she was delivering a load for the visual survey, and were given instructions to tip in the designated area for visual observation. Weigh tickets were obtained from the scalehouse for each load.

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The MSW Team subsequently consulted the InfoUSA database to obtain estimated employment for each targeted load, and also requested service level data from the participating haulers. Table 3-8 summarizes the employment, container yardage, and service levels for each of the 33 commercial organizations that were captured in the study (one of which was sampled twice).

Table 3-8 Visual Survey Waste Generation Business Name NAICS 2-

Digit Number of Employees

Container Yardage

Container Type[1]

Annual Pulls

Contemporary Classics 31 200 40 CC 156 Sia Abrasives 32 23 40 CC 9 Intelicoat Technologies#3 32 150 40 CC 104 Stock Building Supply 32 70 40 CC 104 CCL Label 32 100 42 CC 156 Cadmus Specialty Packaging 32 300 42 CC 312 Rutland plastic 32 100 30 SC 104 Sun Chemical 32 113 30 SC 104 Pelton & Crane 33 201 40 OT 156 Aplix (sampled twice) 33 50 30 SC 104 Jacobsen 33 200 40 CC 52 Pelton Crane 33 201 40 CC 156 Carocraft Cabinets 33 40 40 OT 156 United Supply 33 118 40 CC 24 Scandura/Fenner Dunlap 42 65 40 CC 52 Home Depot 44 120 40 OT 52 Sears 44 19 40 CC 17 Building Center Inc. 44 100 40 CC 17 Harris Teeter 44 87 30 SC 52 Value City 44 35 40 CC 60 Lowes Food 44 120 30 CC 52 Family Dollar DC Box 1 45 400 42 CC 52 Family Dollar DC Box 2 45 400 40 CC 104 Costco 45 18 30 SC 104 Stein Mart 45 52 40 CC 18 Belk Dist Ctr 45 250 40 CC 52 Wal-Mart 45 48 30 SC 52 Canteen Vending 45 275 40 OT 104 Marshall's 45 47 40 CC 156 Wal-mart 45 48 30 SC 36 FedEx Ground 48 30 SC 52 Britax 54 180 30 SC 26

IPEX 99 150 30 SC 156

[1] OT = Open Top; CC = Compacter; SE = Self-Contained Compactor

The results of these targeted loads were integrated into the on-site survey data to develop combined results.

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3.3. CONSTRUCTION AND DEMOLITION SECTOR APPROACH The construction and demolition sector has been defined in this study to include all construction, renovation, and demolition activities taking place in Mecklenburg County where C&D debris is generated. The MSW Team used multiple strategies to gather information about the generation and management of pallets and clean wood (as well as the other targeted materials) in the C&D sector. Our approach for researching the C&D sector encompassed the following efforts:

Hauler surveys to inquire about the incidence of generation, alternative disposal options, and procedures for collecting pallets and clean wood from C&D sites;

Full C&D characterization analysis that took place at two C&D disposal facilities in Mecklenburg County that collectively receive about 80 percent of the total C&D waste generated; and

Builder focus group meetings were used to get direct feedback from builders and developers who are active in both residential and commercial development and construction in the County.

Specific research performed for the commercial sector is described below.

3.3.1 HAULER SURVEYS At the time of the study, there were a total of 15 permitted haulers2 that were collecting C&D waste in Mecklenburg County. The vast majority of the C&D debris being collected by these haulers was likely to be delivered to C&D landfills (or facilities other than MSW landfills), so it was not believed that the wood pallet ban in MSW landfills would be as problematic for these haulers and their customers. However, in an attempt to capture some insight about on-site management practices for wood pallets and clean wood from C&D haulers, the MSW Team conducted a brief survey of the C&D haulers. MSW developed a cover letter and survey instrument to guide the responses, and contacted haulers by phone and e-mail to request participation. Twelve of the 15 C&D waste haulers provided at least some feedback from the survey, with the other three not responding to our inquiries or declining to participate. Appendix B contains the survey instrument and a matrix of survey responses.

3.3.2 C&D WASTE CHARACTERIZATION STUDY Over the past several years, Mecklenburg County has generated roughly 350,000 tons per year of C&D that has been disposed in landfills. C&D waste is known to contain a large fraction of materials that can be recycled and, according to the County’s 2006 Solid Waste Master Plan, C&D represents “the greatest single opportunity for waste reduction.”

As part of this overall study of wood pallets, clean wood, and other materials, MSW Consultants conducted a full C&D waste characterization study to investigate the composition of County-generated C&D being disposed in landfills. This study was performed to achieve the following objectives:

2 Eleven of these haulers were reported to only collect C&D wastes, with four collecting from all sectors.

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Develop statistically defensible estimates of the annual composition of C&D waste generated in Mecklenburg County and disposed in landfills;

Identify opportunities for increasing diversion from this sector; and

Establish a baseline snapshot of the composition of Mecklenburg County’s C&D waste stream against which future studies can be compared for the purpose of evaluating future programmatic changes.

According to C&D disposal data that were compiled from annual landfill reports to the North Carolina Department of Environment and Natural Resources (DENR), Mecklenburg County generated 377,120 tons of C&D waste in FY2007. This C&D was reported by eight different C&D landfills inside and outside of Mecklenburg County. However, 76 percent of County-generated C&D was reported to be disposed at two facilities: the County’s Foxhole Landfill on Mecklenburg County’s southern border, and the North Mecklenburg Landfill in Cornelius, serving the northern part of the County.

In the Summer and early Fall of 2007, MSW Consultants arranged and conducted a total of three weeks of on-site sampling of incoming C&D loads at these two facilities. During field data collection, a total of 246 loads were randomly selected for sampling. For each load, MSW Consultants applied a visual surveying protocol to identify the prevalence of 30 discrete materials in the C&D waste stream. The visual surveying protocol required a professional field supervisor with solid waste industry experience to:

Measure the dimensions of the incoming truck or container;

Estimate how full the container is on a percentage basis;

Systematically identify and estimate the volume-percent of the constituents in the load; and

Acquire the actual weight ticket from the facility scalehouse indicating the actual weight of the load.

Volume-based estimates were converted to weights based on industry-standard density factors, and the resulting estimated weight was normalized based on the actual known weight of the load. Landfill based sampling of incoming waste streams are believed to render the most accurate picture of the composition of these waste streams. A separate, comprehensive report was developed to summarize the methodology and results of the Mecklenburg County C&D waste characterization study. For the convenience of the reader, detailed tabular results of the entire C&D waste stream are shown in Table 3-9, and the results section of the full C&D report is included in Appendix F to this volume.

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Table 3-9 Mecklenburg County C&D Waste Composition Summary

90% Conf. Interval

Material Categories Mean Standard Deviation Lower Upper

Annual Quantity (Tons)

OCC/Kraft 3.8% 0.4% 3.1% 4.5% 14,302 Other Paper 0.7% 0.1% 0.6% 0.9% 2,817

Paper Subtotal 4.5% 0.5% 3.7% 5.3% 17,119 PVC Pipe 0.1% 0.0% 0.1% 0.2% 457 Plastic Film 0.3% 0.1% 0.2% 0.4% 1,283 Vinyl Siding 0.1% 0.0% 0.0% 0.1% 194 Other Plastic 0.6% 0.1% 0.5% 0.7% 2,191

Plastic Subtotal 1.1% 0.1% 0.9% 1.3% 4,125 Glass 0.9% 0.1% 0.7% 1.1% 3,420

Glass Subtotal 0.9% 0.1% 0.7% 1.1% 3,420 Appliances 0.1% 0.0% 0.0% 0.1% 217 Other Ferrous Metals 5.6% 0.7% 4.4% 6.8% 21,174 HVAC Ducting 0.1% 0.0% 0.0% 0.1% 290 Other Non-Ferrous Metals 1.1% 0.1% 0.9% 1.4% 4,321

Metal Subtotal 6.9% 0.8% 5.6% 8.2% 26,003 Land Clearing / Limbs / Stumps 0.9% 0.3% 0.4% 1.4% 3,514 Other Yard Waste 1.1% 0.2% 0.7% 1.5% 4,162

Green Waste Subtotal 2.0% 0.4% 1.4% 2.7% 7,676 Concrete/ Block/ Brick/ Stone/ Tile 23.3% 3.1% 18.2% 28.4% 87,846 Dirt/Sand/Gravel 6.1% 1.3% 4.0% 8.2% 23,046

Inerts Subtotal 29.4% 3.4% 23.9% 34.9% 110,892 Pallets 2.1% 0.3% 1.6% 2.5% 7,765 Crates 0.5% 0.3% 0.0% 0.9% 1,856 Untreated Wood 16.5% 1.4% 14.2% 18.8% 62,252 Oriented Strandboard (OSB) 6.0% 0.8% 4.7% 7.3% 22,488 Treated/ Painted/ Processed Wood 6.8% 0.7% 5.7% 7.8% 25,505

Wood Subtotal 31.8% 2.2% 28.2% 35.4% 119,865 Drywall - Unpainted 6.8% 1.1% 5.0% 8.7% 25,806 Drywall - Painted 0.4% 0.2% 0.1% 0.7% 1,613 Asphalt Roofing 6.4% 1.2% 4.4% 8.4% 24,084 Insulation 0.8% 0.2% 0.5% 1.0% 2,888 Ceiling Tiles 0.1% 0.0% 0.0% 0.1% 292 Carpet & Carpet Backing 5.3% 1.0% 3.7% 7.0% 20,167

C&D Materials Subtotal 19.8% 1.9% 16.7% 23.0% 74,850 Bagged MSW 1.3% 0.2% 1.0% 1.6% 4,867 Electronics 0.0% 0.0% 0.0% 0.1% 173 Bulky Wastes/ Furniture 0.9% 0.2% 0.6% 1.2% 3,344 Mixed C&D/ Other Unclassified 1.3% 0.2% 1.0% 1.6% 4,784

Bulky/Other Subtotal 3.5% 0.4% 2.9% 4.1% 13,168

TOTAL 100.0% 377,120

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3.3.3 BUILDER FOCUS GROUPS As a final task to gain qualitative feedback from the building community on recycling in general and on the issue of pallet and clean wood recycling specifically, the MSW Team, in cooperation with Mecklenburg County, hosted two focus group meetings attended by local builders. The first focus group meeting was held on December 11, 2007, and was attended primarily by commercial builders. The second focus group meeting was held on December 13, 2007, and was attended by residential builders.

Prior to each focus group meeting, the MSW Team prepared an agenda and a list of questions to be covered in the meeting. A copy of the focus group agenda and questions is included in Appendix F. The MSW Team supplied a solid waste industry senior professional with extensive facilitation experience, as well as a note taker, to support each focus group meeting. Focus group meetings were also attended by one or more County representatives, as well as one or more members of the MSW Team to observe.

During each meeting, the MSW Team spent several hours progressing through the questions and soliciting responses from attendees. Attendees were addressed by their first names, and no company-specific information was retained beyond a general description of the type of construction in which each builder specialized. In general, the focus group attendees were believed to be reasonably open and frank in their responses, a summary of which can be found in Appendix F.

3.4. RECYCLING MARKET RESEARCH APPROACH As described previously, a significant percentage of this study focused on characterizing the generation and on-site management of wood pallets, clean wood, and the other targeted materials. The remaining focus of the project was to research and assess the available infrastructure within the Mecklenburg County regional market area for collecting, reusing and recycling the targeted materials. This infrastructure consists of:

Permitted and non-permitted collectors (and self-haulers) of these materials;

Re-manufacturing/reuse facilities for wood pallets;

Wood grinders who chip pallets for use in mulch/landscaping and boiler fuel applications; and

Processors or end-users who may use the other targeted materials as a feedstock or otherwise prepare any of the targeted materials for resale to end users.

It should be noted that at the current time there are no material recovery facilities (MRFs) in Mecklenburg County that target the C&D waste stream. Additionally, other than OCC, there are no local MRFs that accept mixed loads containing the remaining targeted materials that have not been source separated.

The following sections describe the market research performed.

3.4.1 COLLECTION INFRASTRUCTURE RESEARCH As described above, the MSW Team made inquiries to the licensed haulers in Mecklenburg County to gain feedback. However, the bulk of the research on the collection infrastructure was secondary in nature and was based on comments made by pallet and wood generators

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and/or by the pallet recyclers in the County that receive small (pick-up truck) loads of pallets from a relatively large number of unlicensed individuals that earn incremental revenue by scavenging pallets. Due to the fact that these scavengers are not listed in the phone book, and in most cases the pallet generators did not know specifics, the MSW Team has not surveyed these entities.

3.4.2 SURVEYS OF MARKET INFRASTRUCTURE Mecklenburg County has a robust pallet recycling and rebuilding industry. Based on the list of pallet recyclers provided by the County, and confirmed in the field, there are 16 pallet recyclers serving the region, seven of which are large operations each handling between approximately 200,000 and 2 million pallets per year. The MSW Team performed on-site visits to six of the seven large recyclers, and developed estimates of how many used pallets each recycled annually. An estimate for the seventh (which declined to participate in this study) was generated using data the company provided on their web site. Of the remaining pallet remanufacturers, four were interviewed by telephone, and seven were not contacted. The MSW Team also contacted and in some cases visited other clean wood (grind) end users. Table 3-10 summarizes the primary research conducted for local pallet and clean wood markets.

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Table 3-10 Summary of Pallet/Wood Market Infrastructure Participants

Material Company Name Contacted Notes

Custom Pallet Visited Also grind wood

Gamble Visited Remanufacture only

IFCO Visited Remanufacture only

Metromont Visited Also grind wood

Neal's Visited Also grind wood

Simpson Visited Remanufacture only

Starnes Data obtained from web page

Remanufacture only

LA Brick Phone Small volume remanufacturer

Pallets and Such Phone Small volume remanufacturer

Accu-Pak Not contacted Small volume remanufacturer

Blue Ridge Not contacted Small volume remanufacturer

Hwy 49 Not contacted Small volume remanufacturer

Johnny Brown Not contacted Small volume remanufacturer

Statesville Not contacted Small volume remanufacturer

Tree Brand Not contacted Small volume remanufacturer

Workmans Not contacted Small volume remanufacturer

Edwards Phone Virgin pallet producer only

First Alliance Phone Broker only

Piedmont

AmWare Visited Closed system

Wood Pallet Markets

Foxhole Landfill Data provided by County

Pallet and clean wood grind

Stone Phone

Bowater Phone

Chester Phone

Conweb Phone

Biofuels Inc Phone

Sunoco Phone

Users of grind

Compost Central Visited Does not accept pallets

[1] These NAICS codes were not initially targeted in the on-site surveys; rather, these establishments were observed to have pallets awaiting recycling or disposal and were added to the list of on-site surveys while the field study was in progress.

In addition to the markets for wood pallets and clean wood, the MSW Team also contacted end markets or processors for the other materials targeted in the study to inquire about

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current capacity, barriers and opportunities for expansion, and other pertinent data about the local market for these materials. In all, the MSW Team contacted over a dozen entities that potentially serve as a market for gypsum, plastic film, OCC, vinyl siding, or asphalt shingles.

3.5. OTHER INFORMATION SOURCES To supplement the primary research described above, the MSW Team was also provided a copy of relevant reports and data sets to supplement the research that was undertaken for this project:

The Recovery of Construction and Demolition Wood Waste for Use as a Boiler Fuel, April 2007: This is an engineering report that evaluates the use of C&D wood waste as a boiler fuel for coal-fired power plants. It identified Duke Power as a potential user of this alternative fuel, provided a C&D material recovery facility is developed in the County.

Commercial Waste Characterization Study, Mecklenburg County, January 2006: This study relied on a desktop estimate of the likely generation and composition of commercial waste. While the study appeared well researched and useful for planning purposes, it acknowledges that disposal site sampling of commercial wastes would be preferable to develop County-specific data.

Mecklenburg County Solid Waste Management Plan 2006 – 2016: This document was consulted for waste generation data and projections for the commercial and C&D generator sectors.

County-managed Surveys of C&D and Commercial Generators: The County is active in promoting recycling, reuse and source reduction practices within its commercial and C&D sectors, and has made outreach efforts in the past. Copies of relevant survey data was provided for review by the MSW Team.

Where applicable, these studies were used to supplement the findings of this project.

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4. WOOD PALLETS AND UNTREATED WOOD

4.1. INTRODUCTION

The primary focus of this project was to document the generation, collection, recycling/reuse, and disposal of wood pallets and clean wood waste. This section presents the breadth of information that was derived in this study on these two materials. Further, this section attempts to draw conclusions about the ability of the recycled market infrastructure to manage these materials, with special focus on the impending ban on wood pallet disposal in municipal solid waste landfills which goes into effect on October 1, 2009.

The section is organized in the following subsections:

Wood Pallet Generation, Disposition and Recycling,

Untreated Wood Waste Generation, Disposition and Recycling,

Transportation and Recycling Market Infrastructure Analysis, and

Gap Analysis and Implications of the Pallet Ban.

4.2. WOOD PALLET GENERATION, RECYCLING AND DISPOSITION

While pallet generation was documented for a wide range of industries, wood pallets were found to be generated in large numbers among a relatively small number of commercial sectors, as well as to a significant degree within the construction and demolition waste stream. This section summarizes the results of our analyses of pallet generation and disposition.

4.2.1 COMMERCIAL SECTOR

4.2.1.1 Survey Results On-site and telephone surveys were used in combination as the primary means of assessing pallet generation, recycling, and disposal in the commercial sector. Significant amounts of data were generated in the course of these survey efforts. Findings of note are provided in tabular and graphical format.

Recall that the approach for this project involved segregating the universe of businesses into three strata:

Likely Generators,

Possible Generators, and

Unlikely Generators (i.e., businesses not surveyed).

Results of the surveys for both the Likely and the Possible Generators are shown.

Table 4-1 summarizes the percentage of respondents to both the telephone and on-site surveys of the Likely generators that reported or were found to generate wood pallets.



Table 4-1 On-Site and Telephone Surveys of Likely Pallet Generators

Phone Surveys On-site Surveys

NAICS Code

Industry Surveyed Generate Pallets

Percent Surveyed Generate Pallets

Percent

31-33 Manufacturing 31 12 38.7% 55 48 87.3%

42 Wholesale Trade 62 32 51.6% 95 72 75.8%

44-45 Retail Trade 42 22 52.4% 82 52 63.4%

48-49 Transportation/Warehousing 17 4 23.5% 21 18 85.7%

56 Admin/Support/Waste Mgmt 3 1 33.3% 3 2 66.7%

62 Health Care 3 1 33.3% 6 2 33.3%

71 Arts/Recreation 3 1 33.3% 3 2 66.7%

Total 161 73 45.3% 275 205 74.5%

As illustrated in Table 4-1, the on-site surveys reflect a significantly higher incidence of pallet generation within the same universe of Likely Generators compared to the telephone surveys. In total, on-site surveys identified pallet generation at 60 percent more businesses compared to the phone survey (stated another way, for every one business identified as generating pallets in the phone survey, 1.6 businesses were identified as generating pallets via on-site survey). This outcome suggests that on-site surveyors were much better able to identify that pallet generating activities are taking place, and it can be inferred that subsequent survey responses are more accurate and comprehensive as well. For this reason, the Project Team has relied on the on-site survey results for use in our analysis of Likely generators.

No on-site surveys were conducted at businesses pre-classified as Possible Generators. Rather, more extensive phone surveying was conducted for these businesses. Table 4-2 summarizes the results of the Possible Generator phone survey. Note that, as expected based on the random selection process that was used to select businesses, the phone surveys were distributed across all of the industry groups in Mecklenburg County in rough proportion to the number of businesses in each industry group.

Table 4-2 Phone Survey of Possible Pallet Generators

Phone Surveys

NAICS Code


Percent

21 Mining/Quarry/Oil/Gas 1 0 0.0%

22 Utilities 2 1 50.0%

31-33 Manufacturing 5 2 40.0%

42 Wholesale Trade 3 1 33.3%

44-45 Retail Trade 71 14 19.7%

48-49 Transportation/Warehousing 3 0 0.0%

51 Information 17 1 5.9%

52 Finance/Insurance 36 0 0.0%



Phone Surveys

NAICS Code


Percent

53 Real Estate/Rental/Leasing 35 4 11.4%

54 Prof./Scientific/Technical 52 1 1.9%

55 Management 1 1 100.0%

56 Admin/Support/Waste Mgmt 25 5 20.0%

61 Educational Services 7 0 0.0%

62 Health Care/Social Svc. 24 3 12.5%

71 Arts/Entertainment/Recreation 6 1 16.7%

72 Accommodation/Food Services 41 1 2.4%

81 Other Services 36 4 11.1%

Total 365 39 10.7%

As shown in the Table 4-2, the incidence of pallet generation among the Possible Generators decreases significantly compared to that of the Likely Generators. Whereas 45 percent of the Likely Generators contacted via the phone survey reported generating pallets, only 11 percent of the Possible generators contacted by phone reported generating pallets.

However, as illustrated in Table 4-1, above, it is likely that the telephone respondents under-reported the generation of pallets, with 45 percent of Likely Generators reporting that they generated pallets in the telephone survey, while 75 percent said they generated pallets based on the on-site surveys.

Although the MSW Team’s surveyors were trained to coach a respondent in best answering survey questions, phone survey responses could not be visually verified. The MSW team believes that there is a systematic difference between on-site and phone surveys, and that the responses shown in Table 4-2 undercount the number of Possible Generator businesses generating pallets. To make up for this under-reporting, the MSW Team has adjusted the phone survey responses from the Possible Generators upward based on the difference between the Likely Generator phone and on-site surveys. Specifically, the results for Possible Generators have been increased by 64.5 percent.

Based on both the phone surveys (for Possible Generators) and on-site survey responses (for Likely Generators), the MSW team calculated pallet generation coefficients for each industry group for which a sufficient number of samples were obtained. Generator coefficients are stated in terms of the number of pallets per employee per year, and were calculated based on the weighted average generation rate at each of the businesses surveyed. Note that it was not an objective of this study to provide statistically defensible results down to the industry level, and no confidence intervals are reported. (More rigorous statistical treatment of the data would also greatly complicate the presentation of information.)

Table 4-3 presents pallet generation coefficients for Likely Generators derived from over 280 on-site surveys of Mecklenburg County businesses.



Table 4-3 Generator Coefficients of Likely Pallet Generators Based on On-site Surveys (pallets/employee/year)

NAICS Code

Industry Disposed Sent to Recycler

Sent to Chipper

Total Generation

31-33 Manufacturing 2.4 35.9 0.7 39.0

42 Wholesale Trade 5.5 19.1 8.7 33.3

44-45 Retail Trade 2.2 15.4 0.2 17.8

48-49 Transportation/Warehousing 7.7 6.8 0.2 14.7

56 Admin/Support/Waste Mgmt 2.7 0.3 0.0 3.0

71 Arts/Recreation 1.6 4.0 0.0 5.6

Note that the expertise of the on-site surveyor and the ability to discern different outlets for pallets provided a clearer view of how to best quantify pallet disposal and recycling. On-site surveys could readily discern whether pallets were being disposed or recycled, and/or if backhauling was occurring. The decision was made not to focus on backhauled pallets because they were not entering the waste stream and therefore would not be impacted by a ban on disposal. It should be noted however, that the larger pallet recyclers managed large quantities of backhauled pallets over and above the pallets collected through recycling efforts.

Pallets destined for disposal or recycling (whether remanufacture or grinding) were more commonly queued outside the actual facilities where they could be observed and quantified. These pallets were either stacked for pick-up or else may have been placed in roll-off containers for collection. Figures 4-1 and 4-2 show several examples of pallets awaiting collection for disposal or recycling.

Figure 4-1 & Figure 4-2 Pallets Awaiting Collection

Pallets were deemed to be disposed if they were placed in a mixed waste container (dumpster or open-top box). Pallets that were being source separated for recycling were further classified by on-site surveyors as going to a pallet recycler or to a chipper (most commonly to the Foxhole Landfill).

Table 4-4 presents the pallet generator coefficients for Possible Generators based on the adjusted telephone survey results. These results are the direct result of the structure of the phone survey instrument (contained in Appendix D) which, in an attempt to remain simple



enough to be completed quickly over the phone, asked respondents to indicate (a) whether or not pallets were generated at their business, and (b) if so, how the pallets were disposed. The choices for pallet disposition on the survey instrument were given as:

Disposed: Pallets were placed in or around the dumpster for collection with the refuse;

Recycled: Pallets were segregated and collected for delivery to a company that recycles pallets

Backhaul: Pallets were transported, via the company’s supply chain, back to a distribution center for centralized bulk management; or

Reuse: Unloaded pallets were essentially re-loaded and used to transport new (or re-packed) goods for further shipment.

In reality, most businesses may manage pallets in multiple ways, with the intact pallets being reused or back-hauled, the damaged but still salvageable pallets being sent to a pallet recycler, and the pallets that have been damaged beyond repair possibly being disposed. Recognizing that a phone survey would be unlikely to discern so many possible nuances about pallet management, responses were assigned to the pallet management outcome that represented the most pallets. For example, if a company said they both backhaul and recycle, the survey would indicate only the response that was believed to capture the most pallets.

Table 4-4 Generator Coefficients of Possible Pallet Generators Based on Phone Surveys (pallets/employee/year)

NAICS Code

Industry Disposed Recycled Backhaul Reuse Total Generation

31-33 Manufacturing 0.0 0.6 0.0 0.0 0.6

42 Wholesale Trade 0.0 18.6 0.0 0.0 18.6

44-45 Retail Trade 0.1 0.4 1.1 3.0 4.6

48-49 Transportation/Warehousing 0.0 2.8 0.0 0.6 3.4

53 Real Estate/Rental/Leasing 0.0 0.0 0.0 0.0 0.0

54 Prof./Scientific/Technical 0.1 0.2 0.0 0.0 0.3

56 Admin/Support/Waste Mgmt 0.0 0.7 0.0 0.0 0.7

62 Health Care/Social Svc. 0.0 0.0 0.0 0.0 0.0

71 Arts/Entertainment/Recreation 0.0 0.0 0.0 0.0 0.0

72 Accommodation/Food Services 0.0 0.1 0.0 4.7 4.7

81 Other Services 0.0 0.6 0.0 0.0 0.6

Note that these generation rates are significantly below the generation rates of the Likely generators. Of particular interest, pallets were found to be generated in the same industry groups among the Possible Generators. So, although a wholesale trade, retail trade, or transportation/warehousing business might have been screened into the Possible Generator list based on their relatively low employment and small square footage, these establishments were still found in the phone survey to be generating pallets (albeit at lower rates than larger establishments of the same industry group).



Note once again that uncertainty on the part of the respondent about technical details of both generation and disposal or recycling is inherent in phone surveying. Specifically, in many cases the most knowledgeable respondent within a particular company may be able to answer questions conceptually, but cannot quantify the response. For example, many businesses knew they generated pallets; however, it was beyond the ability of the respondent to estimate the number of these pallets; or it was not truly known what fraction of pallets were managed via disposal, backhaul, recycling, or other disposition.

The following tables apply the pallet generator coefficients to the known employment within each industry group to calculate the total number of pallets generated in Mecklenburg County.

Tables 4-5 and 4-6 show the totals for the Likely and Possible Generators, respectively. The Likely Generator totals are based on the on-site surveys, while the Possible Generator totals are based on the adjusted phone survey results.

Table 4-5 Pallet Generation from Likely Pallet Generators Based on On-site Surveys (No. of Pallets)

NAICS Code

Industry Employ-ment

Disposed Sent to Recycler

Sent to Chipper

Total Generation

31-33 Manufacturing 34,235 83,478 1,228,271 23,918 1,335,667

42 Wholesale Trade 29,169 160,577 557,584 253,859 972,020

44-45 Retail Trade 25,193 54,047 388,377 5,325 447,749

48-49 Transportation/Warehousing 15,145 115,846 102,679 3,606 222,131

56 Admin/Support/Waste Mgmt 5,292 14,112 1,764 0 15,876

62 Health Care 13,624 0 0 0 0

71 Arts/Recreation 4,171 6,581 16,684 0 23,265

Total Pallets 122,658 434,641 2,295,359 286,708 3,016,708

Tons 10,866 57,384 7,168 75,418

As shown in Table 4-5, on-site surveys of Likely Generators found that disposal was the least common means of pallet disposition by far, with 85 percent of the pallets either recycled or sent for chipping. This would be considered a very high recovery rate for any material being recycled, and is indicative of the robust pallet recycling infrastructure in place in Mecklenburg County. Most pallets that were not backhauled (or reused) were recycled, with a much smaller fraction observed to be delivered to a wood grinding facility. Table 4-6 Pallet Generation from Possible Pallet Generators Based on Phone Surveys (No. of Pallets)

NAICS Code


Disposed Recycled Backhaul Reuse Total Generation

31-33 Manufacturing 218 0 221 0 0 221

42 Wholesale Trade 176 0 5,375 0 0 5,375

44-45 Retail Trade 2,742 322 1,970 4,822 13,505 20,620

53 Real Estate/Rental/Leasing 1,360 0 6,220 0 1,435 7,655

54 Prof./Scientific/Technical 2,661 51 0 0 0 51

56 Admin/Support/Waste Mgmt 1,184 205 460 0 0 665



NAICS Code


Disposed Recycled Backhaul Reuse Total Generation

62 Health Care/Social Svc. 1,453 0 1,780 0 2 1,782

71 Arts/Entertainment/Recreation 404 0 0 4 4

72 Accommodation/Food Services 1,849 11 0 0 11

81 Other Services 2,530 0 242 0 19,371 19,613

Total Pallets 14,577 589 16,268 4,826 4,313 55,996

Tons 15 407 121 858 1,400

Possible Generators generated a much lower number of pallets per employee compared to Likely Generators, based on phone survey responses. Even accounting for the larger employment in this stratum (360,000 compared to 130,000 employees), the absolute number of pallets generated by Possible Generators was a fraction of the Likely Generators.

Table 4-7 summarizes the pallets being disposed and recycled in Mecklenburg County, based on the analysis above. Note that several assumptions were made to define the term “recycled” from the phone and on-site surveys. Pallets were defined to be recycled if they went to either a pallet remanufacturer or to a chipper (including the Foxhole Landfill)1 during the on-site survey. For the phone surveys, the decision was made to include pallets that were reported to be destined for recycling or backhaul, but not for reuse, in the “recycled” total. This decision was based on the qualitative judgment that survey respondents tended to mention these two responses more frequently and that these responses were more interchangeable.

1 A strict definition of recycling would exclude the use of wood chips for boiler fuel. For this analysis any beneficial reuse of wood pallets was included in the definition of recycling for the sake of simplicity.



Table 4-7 Total Pallet Generation in the Commercial Sector

Disposed Recycled

NAICS Code

Industry Likely Generators

Possible Generators

Total Likely Generators

Possible Generators

Total

31-33 Manufacturing 83,478 0 83,478 1,252,189 221 1,252,410

42 Wholesale Trade 160,577 0 160,577 811,443 5,375 816,818

44-45 Retail Trade 54,047 322 54,369 393,702 6,739 400,441

48-49 Transportation/Warehousing 115,846 0 115,846 106,285 0 106,285

53 Real Estate/Rental/Leasing 0 0 6,220 6,220

54 Prof./Scientific/Technical 51 51 - #VALUE!

56 Admin/Support/Waste Mgmt 14,112 205 14,317 1,764 460 2,224

62 Health Care/Social Svc. 0 0 0 0 1,780 1,780

71 Arts/Entertainment/Recreation 6,581 0 6,581 16,684 4 16,688

72 Accommodation/Food Services 11 11 0 0

81 Other Services 0 0 242 242

Total Pallets 434,641 589 435,230 2,582,067 21,095 2,603,162

Tons 10,866 15 10,881 64,552 527 65,079

Percent of Total 14.3% 85.7%

As noted in Table 4-7, approximately 3 million pallets were estimated to be discarded through means other than back-hauling by commercial pallet generators in Mecklenburg County. Eighty-six percent of these pallets were being recycled, with the vast majority being recycled by Mecklenburg County’s relatively robust pallet recycling infrastructure. Only 14.3 percent of the pallets that are discarded from Mecklenburg County businesses are estimated to have been disposed in MSW landfills. Note that this is a conservative estimate because it is possible that some of these pallets were being delivered to C&D landfills. To be conservative, on-site surveyors classified all pallets in mixed waste boxes as being commercial waste. However, there were some boxes that appeared to contain only materials that are accepted at C&D facilities.

It should be noted that the above estimates exclude pallets generated by the construction industry, which is accounted for below.

As a final exercise, Figure 4-3 below shows the portion of the overall Mecklenburg County commercial waste stream comprised of wood pallets.



Figure 4-3 Pallets as a Percent of Disposed Commercial Waste

As shown in Figure 4-3, the 10,900 tons of pallets that were estimated to be disposed in MSW landfills represent only 1.4% of the 773,000-ton commercial waste stream. This is of interest because it suggests that pallet disposal in MSW landfills is a relatively minor concern at the current time. It may also be of interest that these results suggest that there are fewer pallets in the commercial waste stream compared to prior studies conducted by the County. In the County’s 2006 “desktop” commercial waste characterization study (i.e., the study relied on comparative analysis and estimations but did not include field sampling, sorting, and weighing), it was estimated that there were 15,869 tons of pallets (out of 601,862 tons of commercial waste), or 2.6 percent.

4.2.1.2 QCTS Results While a complete disposal site characterization study was not possible to quantify pallets in commercial waste, the MSW Team was able to perform two days of visual observation at the Queen City Transfer Station (QCTS). The QCTS, located in Charlotte, receives not only commercial waste but also some C&D debris. Figure 4-4 shows the fraction of incoming weight of commercial waste and C&D debris at the QCTS, based only on the two days of field observation performed. The classification of waste as being commercial or C&D was based on the professional judgment of the MSW field supervisor, as it was not possible to interview the driver to confirm the origin of the load.



Figure 4-4 Proportion of Waste Received at QCTS

As shown, the majority of wastes received at QCTS were found to be commercial waste, which was the focus of our study. However, 16 percent of wastes appeared to have originated from C&D related activities.

A total of 117 loads of commercial waste were observed over two days at QCTS. Table 4-8 summarizes the quantities of pallets that were observed to be in commercial wastes.

Table 4-8 Summary of Commercial Waste Deliveries to QCTS

Frontloaders Open Top Rolloffs

Compactors

Percent of Commercial Deliveries 31% 40% 29%

Average Weight per Load 7.8 tons 2.3 tons 5.8 tons

Average Number of Pallets per Load 0.25 11.78 0.68

Pallets as Percent of Load (by Weight) 2.5%

As shown in the table, the facility receives a relatively even mix of frontload, open top roll-off and compactor deliveries containing commercial waste, although the frontloaders and compactor boxes weighing significantly more than the open top boxes. However, wood pallets were observed to be much more prevalent in the open top debris boxes, with an average of 12 pallets per commercial box. Fewer than one pallet was observed, on average, in frontloaders and compactors.

Despite the limitations associated with making these visual observations at QCTS, it is notable that wood pallets were observed in the commercial stream at a roughly comparable level to the findings of the on-site surveys. The MSW Team believes that the QCTS visual



observations support the belief that results of the on-site generator surveys are, ultimately, the most accurate data for use in our projections.

4.2.1.3 Hauler Feedback Mecklenburg County haulers were asked to provide information about wood pallets generated by their customers and managed by each hauler. The following bullets summarize this feedback:

Two of the respondents reported that wood pallets are not generated by their clients (which could be interpreted as being placed in the dumpster for disposal). The other haulers reported that some customers generated pallets;

None of the responding haulers reported pallets in dumpsters as being problematic;

The fraction of commercial customers reported to dispose of pallets in refuse dumpsters was no more than 10 percent, and in most cases in the low single digits;

Warehouses were cited by responding haulers as the primary generator of pallets placed in dumpster for disposal.

Only one hauler reported any customers having a recycling program for pallets. This was interpreted by the MSW Team to mean that that hauler collected source-separated pallets for delivery to a pallet recycler;

Haulers reported delivering pallets to multiple pallet recyclers, although Custom Pallets was mentioned most frequently;

Multiple reasons were given for why customers do not recycle wood pallets, and there was no clear consensus.

The detailed results of the hauler survey are shown in Appendix E.

4.2.2 C&D SECTOR Quantitative information on the C&D waste stream was drawn from a full C&D waste characterization study that was performed as part of this project. This information was supplemented by qualitative feedback from two focus group meetings conducted with area builders, as well as by limited interviews with local permitted haulers. Relevant findings are described below.

4.2.2.1 C&D Waste Characterization Analysis Table 4-9 summarizes the estimated quantity of wood pallets found in the C&D waste stream. The table shows the average, or “best estimate,” as well as the lower and upper confidence intervals at a 90 percent level of confidence. This means that we can be 90 percent sure that the true quantity of pallets lies within the lower and upper bounds shown in the table.



Table 4-9 Wood Pallets in C&D Waste Stream

Percent of C&D Waste

Tons of Pallets

Number of Pallets

Minimum (90%) 1.6% 6,043 241,739

Average 2.1% 7,765 310,593

Maximum (90%) 2.5% 9,486 379,448

Source: Mecklenburg County C&D Waste Characterization Study, September 2008.

The C&D characterization study also provided an opportunity to more closely analyze the size, type and condition of pallets being delivered in this waste stream. Specifically, the MSW Team attempted to individually tabulate pallets being delivered in mixed C&D waste loads. It is important to note that the majority of the pallets arriving in mixed C&D loads were commingled with a variety of debris and it was difficult or dangerous to retrieve and measure these pallets consistently. Furthermore, when the compactor or dozer spread out the tipped loads of C&D, this action effectively damaged many or most of the pallets embedded in the debris pile. Despite these obstacles which limited the MSW Team’s ability to physically extract and characterize pallets from the C&D stream, MSW Consultants tabulated summary shown in Table 4-10, based on visual assessment of over 500 pallets observed during the C&D characterization study.



Table 4-10 Characterization of Wood Pallets in C&D Loads

Characteristic Breakdown No. of Pallets

Percent

Size [1] Standard Size and Construction 247 47.0%

Standard Size, non-standard Construction 185 35.2%

Small 31 5.9%

Oversize 62 11.8%

Subtotal 525 100%

Condition Undamaged 391 74.5%

Intact but Broken Parts 105 20.0%

Not Intact 29 5.5%

Subtotal 525 100.0%

Reusability [2] Reusable for Remanufacture 463 88.2%

Not Reusable (chip/grind only) 62 11.8%

Subtotal 525 100.0%

[1]Pallets could not be uniformly measured for access and safety reasons, and the size tabulations shown in the table are based on best visual estimate of the pallets, rather than precise measurements.

[2]Pallets were classified as being reusable if they were standard sized and intact (including those with some broken parts). Pallets were classified as being not reusable if they were not intact or if they were smaller than standard size. In practice the larger than standard size pallets may be recoverable for use as replacement parts.

As shown in the table above, at an observed rate of 88 percent, wood pallets delivered for disposal in the C&D waste are predominantly reusable for remanufacture of new pallets. However, recovery of pallets from C&D sites would be increased if pallets were source separated and delivered to a pallet remanufacturer prior to collection and delivery to a C&D landfill. While most pallets appeared to be recoverable during our observations, the process of physically removing pallets from mixed C&D waste would be expected to further damage at least a fraction of the pallets observed.

Although the full C&D characterization study provides the most thorough and defensible results, a second data point was obtained based on the QCTS observations. Concurrent with the commercial waste observations at the QCTS, the MSW Team performed a similar analysis on a smaller number of C&D loads. Table 4-11 summarizes the incidence of pallets in the C&D loads entering the QCTS.



Table 4-11 Summary of C&D Debris Deliveries to QCTS


Compactors

Percent of C&D Deliveries 0% 100% 0%

Average Weight per Load NA 4.7 tons NA

Average Number of Pallets per Load NA 0.59 NA

Pallets as Percent of Load (by Weight) NA 0.3% NA

It is of interest that these results differ significantly from the full C&D visual characterization study data. While this is not surprising – the sample size at the QCTS was far too small to be considered representative and it was also not possible to see all sides of each load – it is indicative of the potential error associated with attempting to use non-statistical approaches to defensibly analyze waste compositions. The MSW Team believes the results of the full C&D characterization study are the most accurate and defensible for planning purposes.

4.2.2.2 Hauler Feedback Mecklenburg County C&D haulers were asked to provide information about wood pallets generated at C&D sites and managed by each hauler. The following bullets summarize this feedback:

Residential construction was most commonly cited as the most common generator of pallets. Only one hauler indicated a non-construction generator of pallets – from manufacturing/industrial plants - in open top roll-off as being prevalent;

Only three haulers out of the 13 respondents indicated that they collect pallets from their roll-off customers for recycling. Pallet recycling was provided to between 1 and 15 percent of roll-off customers (which may expand beyond C&D customers); and

Responding haulers generally did not provide where they take pallets for recycling.

The detailed results of the hauler survey are shown in Appendix E.

4.2.2.3 Builder Feedback Two builder focus groups were held to obtain input from builders as to the opportunities and constraints to increasing recycling of C&D materials, including wood pallets and clean wood. The first focus group included builders who focus primarily on commercial construction. The second focus group included builders who focus primarily on residential construction. Both groups included a mix of large and small builders, and all in attendance were active participants. The following bullets highlight notable feedback received from the commercial and residential builders who attended the focus groups.

4.2.2.4 Commercial Builder Focus Group Highlights Commercial builders reported that on average 25 percent of their customers required

recycling – primarily for LEED purposes.

On non-LEED projects the commercial builders typically only recycle metal, which has value, although they will often attempt to send OCC and wood pallets back with the



vendors. They also reported looking for an alternative for concrete because it is costly to dispose of at a landfill. At least one commercial builder reported that disposal of wood pallets can be a problem on small jobs.

On LEED projects the commercial builders recycle a wide array of materials – clean wood, concrete, gypsum, carpet, ceiling tile, light fixtures, metals, and OCC were the items reported most frequently. Because weight is important to the recycling rate for LEED projects, the heavier materials are preferred.

No commercial builder reported recycling film plastic, vinyl siding, or asphalt.

When asked what motivates them to recycle the builders reported, in order of importance: (1) money; (2) LEED certification requirements; (3) customer requirement; and, (4) good publicity. Only one builder reported doing it because it was the right thing to do.

When asked about the importance of cost, there was general consensus that the extra cost of recycling was a deterrent to recycling in many cases. In many cases it is hard to justify the added cost of supervision, container rental, and employee compliance when local landfill tip fees are so low.

Another important barrier noted by builders was the lack of sufficient space to place additional storage containers on many job sites.

Finally, the builders reported that a lack of good information on markets was an issue. Although they recognized county publications existed, they cited the difficulty in contacting markets in real time.

When asked to identify markets for clean wood, about one-half said that with landfill costs so low there was no incentive to recycle wood. Most believed that the primary market was the Compost Central grinder, or another grinder.

When asked about gypsum, builders cited the high cost of transport to the market, as well as the risk of illicit dumping in the roll-off container which contaminated the load. Contamination was reported to be deposited in the containers either by sub-contractors or by the general public (especially over the weekend) unless the dumpster was fenced.

4.2.2.5 Residential Builder Focus Group Highlights Residential builders were much less likely to recycle than the commercial builders. This is

primarily because maintaining low costs was more of a factor for residential construction, and because of the lack of LEED certification incentives.

The most likely items to be recycled were concrete (because of high cost of disposal) and metals (because of its value).

A number of builders did report that they try to reuse materials or use reuse stores if possible, although both the commercial and residential builders reported that new building and fire code requirements often discouraged reuse because the old materials (e.g., doors) would not meet the new codes.

Large residential builders reported that a big deterrent to recycling is the time required to recycle. While they are motivated to not create the waste in the first place, recycling increases supervisor time and responsibility – a typical supervisor on a large residential development might have 25 to 30 houses under supervision. Lining up markets and



containers, sequencing material recycling, supervising sub-contractors and training employees to recycle would add time which is more valuable managing the construction process to reduce cycle time (the time from start to finish of each house).

The builders reported that the waste management companies, while neutral to recycling, do not provide recycling services as a general part of their service.

All of the builders reported that if the County wanted to increase recycling they would have to regulate it so that there was a level playing field.

The residential builders reported that if they had a separate container they would concentrate on OCC, clean wood, and/or gypsum. However they all pointed out that illicit disposal in waste dumpsters is already a large problem – especially on weekends when there are no workers on site. It was suggested that placing additional containers for recycling would only add to the problem – and create significant contamination.

When asked about banning clean wood from disposal, the residential builders raised a series of questions about what constituted “clean wood” – with nails(?), finger jointed with glues(?), oriented strand board and plywood(?). All reported that it would increase their costs and the time for construction so that it would have to be regulated so that all builders had the same restriction.

A number of builders reported that they do make sub-contractors responsible for their own wastes if possible. There was general agreement that on larger projects waste disposal costs were about one percent of costs, and therefore relatively insignificant. However, there was not a lot of incentive to recycle and potentially increase costs.

As with the commercial builders, wood pallets were rarely mentioned as a significant waste management issue.

Complete builder focus group notes are contained in Appendix G.

4.2.3 PALLET RECYCLING/REUSE MARKET RESEARCH As a final step in quantifying the pallet stream in Mecklenburg County, and to assess the potential for the market to absorb additional pallets if they were banned form landfills, the MSW Team performed on-site visits to six of the seven large pallet recyclers and estimated recycled quantities from the seventh using data that company provided on their web site. Telephone surveys were made to four additional pallet recyclers (one the largest new pallet manufacturer in the County, and three small recyclers) to round out the data. Based on the surveys, the MSW Team made an informed assumption (based on the 80/20 percent rule of thumb concerning large and small operations) that the remaining smaller pallet recyclers recycle 20 percent of the total. Table 4-12 shows our estimate of the number of pallets that are handled by the recycling infrastructure annually.



Table 4-12 Estimated Annual Pallet Recycling by Mecklenburg County Infrastructure

Pallet Recyclers Number of Companies

Estimated Number of Used Pallets Accepted per Year

Large Recyclers (1) 7 5,715,000

Small Recyclers (2) 9 1,143,000

Total 16 6,858,000

(1) Large recyclers were defined as those that handle between 175,000 and 2.2 million pallets each.

(2) Small recyclers handled less than 175,000 and were assumed to handle 20% of pallets.

As shown, it is estimated that 6.8 million pallets (rounded) were recycled in 2007 in Mecklenburg County. This number excludes a relatively small number of pallets that may be getting sent directly to wood chipping operations (such as the Foxhole Landfill).

It is important to note that the field research focused on the fraction of these pallets that were being hauled to these pallet recyclers directly from generator sites. Large companies and chains with multiple locations typically have in place sufficient logistical management systems to backhaul their pallets to a central site, and will either manage pallet remanufacture there or else will contract with a pallet manufacturer to perform this function. Our research could not estimate the quantity of pallets that were backhauled out of Mecklenburg County (we did conduct a telephone survey of one firm whom manages pallets from Mecklenburg County in the Chicago area), but we can estimate the number pallets backhauled to Mecklenburg County pallet recyclers by subtracting the number estimated to be hauled directly to the pallet recyclers from the total reported to be handled by the pallet recyclers. Figure 4-5 and Table 4-13 illustrate the number of pallets estimated to be generated in Mecklenburg County, as well as their final disposition.

Figure 4-5 Mecklenburg County Pallet Disposition and Recycling Summary



Table 4-13 Mecklenburg County Pallet Disposition and Recycling Summary

Number of Pallets

Tons Percent

Disposed in MSW LF 445,333 11,133 5.8%

Disposed in C&D LF 310,593 7,765 4.1%

Recycled (including grind) 2,603,162 65,079 34.1%

Backhaul for Recycle 4,254,838 106,371 56.0%

Total 7,613,926 190,348 100.0%

Note that in practice, the number of pallets “generated” in Mecklenburg County may be smaller than shown above for two reasons. First, some of the pallets estimated to be landfilled at C&D landfills may have come from the pallet recyclers. Second, most pallets probably progress through the recycling stage multiple times during the year, and it is not believed that the figures reported by the pallet recycling infrastructure were adjusted for multiple uses of a single pallet. However, for the purpose of estimating the total number of pallets, the MSW Team believes these figures are informative and reasonably reflect the relative disposition of pallets among disposal at landfills or through recycling and reuse.

4.3. UNTREATED WOOD GENERATION, RECYCLING AND DISPOSITION

Unlike pallets, which were somewhat ubiquitous within certain industry groups and within the C&D waste stream, untreated wood was found to be generated primarily in the C&D sector. (Note also that wood pallets that are too small or too damaged for remanufacture are considered clean wood.) This section summarizes the results of our analyses of clean wood generation and disposition.

4.3.1 COMMERCIAL SECTOR

4.3.1.1 Survey Results The stratification of commercial businesses into Likely Generators and Possible Generators, is described above in the pallet discussion. Businesses were characterized inclusive of the likelihood of generating pallets or untreated wood. In other words, Likely Generators included businesses that were deemed likely to generate pallets; or business that were likely to generate clean wood; or both.



Results of the phone and on-site surveys for both the Likely and the Possible Generators are shown in Table 4-14.

Table 4-14 Survey Results of Likely Clean Wood Generators


NAICS Code

Industry Surveyed Generate Wood

Percent Surveyed Generate Wood

Percent

31-33 Manufacturing 31 2 6.5% 55 9 16.4%

42 Wholesale Trade 62 1 1.6% 95 13 13.7%

44-45 Retail Trade 42 4 9.5% 82 9 11.0%

48-49 Transportation/Warehousing 17 0 0.0% 21 1 4.8%

56 Admin/Support/Waste Mgmt 3 0 0.0% 3 0 0.0%

62 Health Care 3 1 33.3% 6 0 0.0%

71 Arts/Recreation 3 0 0.0% 3 0 0.0%

Total 161 8 5.0% 272 33 12.1%

Consistent with the pallet results, the on-site surveys reflect a significantly higher incidence of clean wood generation within the same universe of Likely Generators compared to the phone survey. This once again confirms the MSW Team’s belief that on-site surveyors can better quantify wood generating activities and related management of wood.

No on-site surveys were conducted at businesses pre-classified as Possible Generators; rather, phone surveys were used to inform about wood generation from this stratum of commercial establishments. Table 4-15 summarizes the results of the Possible Generator phone survey.

Table 4-15 Survey Results of Possible Clean Wood Generators

Phone Surveys

NAICS Code


Percent

21 Mining/Quarry/Oil/Gas 1 0 0.0%

22 Utilities 2 0 0.0%

31-33 Manufacturing 5 0 0.0%

42 Wholesale Trade 3 0 0.0%

44-45 Retail Trade 71 0 0.0%

48-49 Transportation/Warehousing 3 0 0.0%

51 Information 17 0 0.0%

52 Finance/Insurance 36 0 0.0%

53 Real Estate/Rental/Leasing 35 0 0.0%

54 Prof./Scientific/Technical 52 0 0.0%

55 Management 1 0 0.0%

56 Admin/Support/Waste Mgmt 25 0 0.0%



Phone Surveys

NAICS Code


Percent

61 Educational Services 7 0 0.0%

62 Health Care/Social Svc. 24 1 4.2%

71 Arts/Entertainment/Recreation 6 0 0.0%

72 Accommodation/Food Services 41 0 0.0%

81 Other Services 36 0 0.0%

Total 365 1 0.3%

It is of particular interest that virtually no businesses across the universe of those surveyed reported any untreated wood generation. While we can be relatively certain that generation would have been underestimated by phone survey respondents, it is nonetheless apparent that untreated wood is not nearly so prevalent in the commercial waste stream as wood pallets.

Based on the on-site survey responses, the MSW Team calculated untreated wood generation coefficients for each industry group for which a sufficient number of samples were obtained. Generator coefficients are stated in terms of the pounds of clean wood per employee per year, and were calculated based on the weighted average generation rate at each of the businesses surveyed

Table 4-16 shows the clean wood generation coefficients derived from over 280 on-site surveys of Mecklenburg County businesses. It should be noted in reviewing Table 4-16 that it is likely that the “Retail Trade” coefficients are skewed by certain types of retail trade that generate large amounts of wood, including a wood stove store, hardware and lumber stores, and nurseries that sell a lot of breakable clay pots.



Table 4-16 Generator Coefficients of Likely Wood Generators Based on On-site Surveys (lbs/employee/year)

NAICS Code

Industry Disposed Recycled Total Generation

31-33 Manufacturing 36 36 72

42 Wholesale Trade 132 15 147

44-45 Retail Trade 105 99 204

48-49 Transportation/Warehousing 0 3 3

56 Admin/Support/Waste Mgmt 0 0 0

62 Health Care 0 0 0

71 Arts/Recreation 0 0 0

Again, the prevalence of clean wood found in the commercial waste stream, even among Likely Generators, was relatively low.

Because of the consistent lack of reported clean wood generation among the Possible Generators, no generator coefficients have been developed and are assumed for the sake of simplicity to be zero. In practice, there is some clean wood being generated by these businesses, but it was not found to be at a level of significance.

The following tables apply the clean wood generator coefficients to the known employment within each industry group to estimate the total quantity of clean wood generated in Mecklenburg County’s commercial sector. Table 4-17 shows the totals for the Likely generators based on the on-site surveys. Although we can reasonably speculate that de mimimus quantities of clean wood are generated in the Possible Generator stratum, we have made no attempt to estimate this amount.

Table 4-17 Wood Generation from Likely Generators Based on On-site Surveys (tons)

NAICS Code


Disposed Recycled Total Generation

31-33 Manufacturing 34,235 605 607 1,212

42 Wholesale Trade 29,169 1,909 217 2,126

44-45 Retail Trade 25,193 1,339 1,248 2,587

48-49 Transportation/Warehousing 15,145 0 12 12

56 Admin/Support/Waste Mgmt 5,292 0 0 0

62 Health Care 13,624 0 0 0

71 Arts/Recreation 4,171 0 0 0

Total Clean Wood 126,829 3,853 2,084 5,937

Percent of Total 64.9% 35.1%

It is notable that over 35 percent of the quantity of clean wood being generated in the commercial sector was found to be destined for beneficial use of some kind. The “recycled” figure in the above Table includes both chipping as well as a range of alternative uses that



were variously reported. Examples of other recycling include: delivery of wood to other manufacturers; distribution of wood to local contractors or employees; and backhauling of wood pieces (which, unlike pallets, were recorded as recycled).

As a final exercise, Figure 4-6 shows the portion of the overall Mecklenburg County commercial waste stream comprised of clean wood.

Figure 4-6 Clean Wood as a Percent of Disposed Commercial Waste

As shown in the Figure, the 3,853 tons of clean wood that were estimated to be disposed in MSW landfills represent only 0.5 percent of the 773,000 ton commercial waste stream. This is far below estimates contained in a prior commercial waste characterization study conducted by the County. In the County’s 2006 desktop commercial waste characterization study, it was estimated that there were 39,196 tons of clean wood (out of 601,862 tons of commercial waste), or 6.5 percent.

4.3.1.2 QCTS Results A total of 117 loads of commercial waste were observed over two days at QCTS. Table 4-18 summarizes the quantity of clean wood that was observed to be in commercial wastes.



Table 4-18 Summary of Commercial Debris Deliveries to QCTS


Compactors


Average Weight per Load 7.8 tons 2.3 tons 5.8 tons

Average Weight of Clean Wood per Load 63 lbs 318 lbs 69 lbs

Clean Wood as Percent of Load (by Weight) 1.7%

Clean wood, like pallets, was observed to be much more prevalent in the open top debris boxes, with an average of over 300 pounds per commercial box. Very little wood was observed in frontloaders and compactors. It is perhaps noteworthy that the visual observations of commercial waste reflect slightly higher percentage of clean wood in commercial deliveries compared to the results of the on-site and phone surveys. The MSW Team believes that the results of the on-site generator surveys are, ultimately, the more accurate data compared to the QCTS observations.

4.3.1.3 Hauler Feedback Mecklenburg County haulers were asked to provide information about clean wood generated by their customers and managed by each hauler. Only two of the haulers providing commercial (dumpster) collection service reported collecting dumpsters with wood from time to time, with estimates that less than five percent of commercial customers disposed of clean wood. None of the haulers responded that clean wood waste problematic. The detailed results of the hauler survey are shown in Appendix E.

4.3.2 C&D SECTOR Relevant findings about clean wood from the full C&D characterization study and from builder focus groups are described below.

4.3.2.1 C&D Waste Characterization Analysis Table 4-19 summarizes the estimated quantity of clean wood found in the C&D waste stream. The table shows the average, or “best estimate,” as well as the lower and upper confidence intervals at a 90 percent level of confidence. This means that we can be 90 percent sure that the true quantity of clean wood lies within the lower and upper bounds shown in the table.



Table 4-19 Clean Wood in C&D Waste Stream


Tons of Wood

Minimum (90%) 14.2% 53,443

Average 16.5% 62,252

Maximum (90%) 18.8% 71,060


Although the full C&D characterization study provides the most thorough and defensible results, a second data point was obtained based on the QCTS observations. Concurrent with the commercial waste observations at the QCTS, the MSW Team performed a similar analysis on a smaller number of C&D loads. Table 4-20 summarizes the incidence of clean wood in the C&D loads entering the QCTS.

Table 4-20 Summary of Clean Wood in C&D Debris Deliveries to QCTS


Compactors


Average Weight per Load NA 4.7 tons NA

Average Weight of Clean Wood per Load NA 552 lbs NA

Clean Wood as Percent of Load (by Weight) 5.9%

Similar to the pallet results, the amount of clean wood observed during the QCTS observations was significantly lower than the full C&D characterization study. Although some of the difference could be attributable to the small sample size the QCTS, it is more likely that the obstacles to accurate visual observations played a more important role. The MSW Team believes the results of the full C&D characterization study are the most accurate and defensible for planning purposes.

4.3.2.2 Hauler Feedback Mecklenburg County C&D haulers were asked to provide information about clean wood generated at C&D sites and managed by each hauler. The following bullets summarize this feedback:

Haulers indicated that between zero and 100 percent of their C&D customers generate wood pallets, and several haulers could not estimate the percentage; and

Only three haulers indicated that they collect clean wood from their roll-off customers for recycling, and two of these haulers indicated minimal quantities of clean wood. One hauler reported recycling wood from 20 percent of their roll-off clients (which may expand beyond C&D customers).

The detailed results of the hauler survey are shown in Appendix E



4.3.2.3 Builder Feedback The majority of builders reported that they did not recycle clean wood, primarily because of the relatively low cost of landfill disposal. For a complete discussion of the factors impacting clean wood recycling, see Section 4.2.2.3.

4.3.3 SUMMARY DISCUSSION This study attempted to estimate the quantity of clean wood generated in Mecklenburg County through a combination of methods. Of the methods used, the on-site surveying of generators was most effective for the commercial sector, while the full C&D characterization study worked best for the C&D waste stream.

Figure 4-7 and Table 4-21 illustrate the quantity of clean wood estimated to be generated in Mecklenburg County, as well as their final disposition.

Figure 4-7 Mecklenburg County Clean Wood Disposition and Recycling Summary

Table 4-21 Mecklenburg County Clean Wood Disposition and Recycling Summary

Tons Percent

Disposed in MSW LF 3,853 5.7%

Disposed in C&D LF 62,252 3.1%

Recycled (including grind) 2,084 91.3%

Total 68,189 100.0%

As shown, the vast majority of clean wood appears to be being disposed, mostly in C&D landfills.



4.4. TRANSPORTATION AND RECYCLING MARKET INFRASTRUCTURE

Being constructed of clean wood (predominantly), pallets have a longer and more varied life cycle than clean wood and as shown above, can be reused multiple times before reaching the end of their useful life as pallets. However, both pallets and clean wood share certain options for beneficial use at the end of their life. This section discusses the collection and recycling market infrastructure for both pallets and clean wood.

4.4.1 COLLECTION AND TRANSPORTATION Mecklenburg County is home to a robust pallet remanufacturing industry, and also offers several outlets for the grinding and recovery of clean wood. These markets are served by both permitted haulers as well as (for pallets) a surprisingly large community of small, unlicensed scavengers. This section explores the infrastructure for collection and delivery of pallets and clean wood to the various end markets in and around the Mecklenburg County region.

During the on-site survey of Likely generators, the MSW Team attempted to record how pallets were collected and transported to recycling companies (exclusive of backhauling for reuse). The collection of pallets was found to be provided by contractual collection, self-haul, and an informal scavenging system. The breakdown of businesses reporting each type of collection is shown in Figure 4-8. Note that this figure tabulates the breakdown of collection method based on the number of businesses, not by the number of pallets being transported (scavengers collect a much smaller fraction of the absolute number of pallets). Note also that this figure excludes back-haul transportation, which was assumed to be performed by equipment and/or other transportation contracts in place with the Mecklenburg County business and its regional distribution center.

Figure 4-8 Pallet Collection and Transportation at Surveyed Businesses



For smaller generators, there exists a significant informal scavenging system. The system consists of many individuals driving around in their own pick-up trucks collecting pallets from loading docks and other areas where they collect at businesses. The scavengers take the pallets to a pallet recycler who pays money for the pallets – usually between $1 and $2 for a standard 40x48 in good condition. Some of these individuals do this as an income supplement, while there are also some who have made it their sole vocation.

Over 60 percent of pallet-recycling businesses visited as part of the on-site surveys knew that this informal infrastructure existed, and placed their waste pallets in locations where they knew pallets would be taken. This practice was widespread throughout the County.

Estimates from pallet recyclers are that about 20 percent of pallets come in to their facilities via this informal system. One pallet recycler reported that he deals with 20 or more of the individual collectors himself, while another estimated that there are over 100 in the County. It is of interest that, although scavengers were found to collect from over 60 percent of businesses, they are handling only approximately 20 percent of the total volume of pallets.

Broadly speaking, the informal scavenging system appears to be providing a clear benefit to the County as a means of recovering used pallets that would otherwise be disposed. It was beyond the scope of this study to investigate the appropriateness of the scavenging or the rationale for regulating such scavenging in any way.

Conversely, based on feedback received, one of the limitations with this informal system is that many of the scavengers will only collect pallets for which they can be paid. While there are certain sizes of pallets that are more commonly used and therefore more desirable (discussed below), a rule of thumb is that a pallet must have at least one dimension of 40 inches to be re-usable in any manner. Therefore, the scavengers were found to leave behind broken and undersized pallets, which would then be destined for the dumpster, given the relatively low cost of disposal.

It was also of interest that several businesses reported developing their own policy for working effectively with scavengers. These businesses demanded that any scavenger of pallets be required to take the bad ones along with the good ones. While this strategy was found to assure removal of small and broken pallets from the generator property, it was reported by pallet recyclers that the result is often illicit disposal of the pallets that they do not purchase.

4.4.2 PALLET RECYCLERS/REBUILDERS Based on the list of pallet recyclers provided by the County, and confirmed in the field, there are 16 pallet recyclers serving the region, seven of which are large operations each handling between approximately 200,000 and 2 million pallets per year. As discussed, these Mecklenburg County recyclers are estimated to recycle roughly 6.8 million pallets annually.

The majority of the pallets brought to the pallet recyclers are refurbished and resold. Refurbishment might consist of simply sorting by size and reselling; repair of one or more broken slats; or cutting the pallet apart for use in refurbishing other pallets.

The size of the pallet is important with respect to the ability of a pallet recycler to use the pallet. One of the medium sized pallet recyclers reported that they recycle the following size pallets (in inches):

48x40



48x48

44x44

45x45

36x36

Because the “standard” pallet (often called a “GMA” pallet because it is the standard size for Grocery Manufacturers Association stores) is typically a 48x40 inch pallet, any pallet with one dimension equal to, or longer then, 40 inches can generally be used to refurbish other pallets – especially the standard pallet. As these sizes listed above indicate, pieces from a 48x48 pallet can be used to refurbish all of the pallet sizes that this pallet recycler refurbishes, while a 36x36 pallet can only be used to refurbish the same or a smaller pallet. For this reason, pallets smaller than 48x40 are the most difficult to recycle, and therefore are the pallets most likely to be thrown away.

According to one of the pallet recyclers, roughly 20 percent of pallets are smaller than the standard pallet (48x40). Since more than one pallet recycler reported recycling smaller sized pallets, it is probably reasonable to assume, therefore, that less than 10 percent of all pallets available for recycling are not being recycled because of their small size. These pallets are typically ground (see below).

In addition, pallets that are made with less than standard thickness slats, or are made of particle board or oriented strand board (OSB) are also very difficult to recycle, and therefore are more likely to be thrown away. However, according to one of the largest pallet recyclers in Mecklenburg County, these off-spec pallets typically make up less than five percent of the pallets in use.

In summary, from 85 to 88 percent of all pallets generated in Mecklenburg County can be recycled directly – either through repair, or by tearing them apart for use in refurbishing other pallets. The remainder would need to be ground for other uses. Of this amount, national studies have estimated that five percent of pallets are too damaged to reuse and are chipped, with less than one percent landfilled.2

4.4.3 GRINDERS There are currently four primary grinding operations in Mecklenburg County:

Compost Central (County owned);

Metromont,

Neals Pallet Company, and

Custom Pallet.

Metromont and Neals Pallet Company both sell the bulk of their ground material to Bowater as boiler fuel. At the time of our interviews with these two companies, Bowater was only paying $6 to $7 per ton for the ground material. According to both Metromont and Neals Pallet Company, this is essentially what it costs to grind a ton of pallets/clean wood (estimated

2 Source: “Recovery, Reuse and Recycling by the United States Wood Packaging Industry: 1993 to 2006,” by Robert Bush, Philip Araman, and E. Brad Hager.



at $3/ton) and transport it to Bowater. As a consequence, companies grinding pallets are doing so only to avoid the disposal fee, if the pallets are their own, or they have to charge other pallet recyclers to grind the material.

Custom Pallet has recently expanded their grinding operation, and is actively seeking higher value outlets for the ground material than for boiler fuel. They are currently3 looking for an additional 40 tons per day of clean wood and pallets for grinding. They are charging $60 per 45 cubic yard trailer dropped off at their yard.

Compost Central currently charges $16.50 per ton to accept wood for grinding. They are currently selling 10,000 cubic yards per year of ground wood as mulch, with all the remaining ground material delivered to one of three boilers:

Bowater: 28 miles away, paying $7 per ton;

Stone: 110 miles away, paying $14 per ton; and,

Chester Wood Products: 40 miles away paying $14 per ton.

According to Steve Elliot, Yard Waste Operations Manager, all three of these facilities are at capacity. In order to free up capacity, Steve believes that he can increase sales of mulch (colored and natural) by an additional 10,000 cubic yards (roughly 2,000 tons at 400 lbs/yard) over the next several years, thereby reducing the supply to the three boilers which would then be available for other grinders.

All of the grinding operations interviewed by the MSW Team would support a ban on pallets to MSW landfills. They believe that this would allow them to charge a fair price for grinding, making it worthwhile to continue to grind clean wood. The key is to find alternative markets for the ground material.

As discussed above, Custom Pallet believes that they have markets for an additional 40 tons of ground clean wood per day. This is roughly equivalent to 10,550 tons per year. In addition, Compost Central believes that they can increase mulch sales by roughly 2,000 tons per year, for a combined total new demand of 12,500 (rounded) tons of ground wood. This is equivalent to roughly all of the pallets currently estimated to be going to MSW landfills from likely pallet generators (445,102 pallets per year).

4.5. GAP ANALYSIS AND IMPLICATIONS OF THE PALLET BAN

One of the primary objectives of this study was to determine the potential impacts of the October 2009 pallet ban. In theory, if the collection and recycling infrastructure were “perfect,” in other words if all pallets could be collected and either recycled or otherwise ground for beneficial end use, there would be no gap between the generation of pallets and the ability of the market to collect and use (reuse) the pallets.

In practice, even though pallets are largely recycled already, there are still pallets that do not get diverted from MSW landfill disposal and therefore would be the target of the pallet ban. This section identifies the entities that stand to be impacted by the ban, and attempts to

3 E-mail correspondence, April 9, 2008



quantify the impact. Because pallets have overlapping end uses with clean wood, the market for clean wood processing is interrelated and is also discussed here.

It should be noted again that the County already enjoys a very high recycling rate for pallets. At 87 percent, the pallet recycling rate is already enviable and compares favorably with the recycling rates of most other targeted recyclables. So in some respects, this is a moot issue, and it is highly unlikely that the recycling rate would increase greatly after the ban takes effect.

The only condition which might trigger a meaningful change in the current pallet recycling rate would be the use of strict, aggressive and costly enforcement methods. For example, if enforcement officials were stationed at the tipping face of MSW landfills, and were empowered to fine commercial haulers a meaningful dollar amount for every pallet that was unloaded, it is possible that this would have the trickle down effect of pushing pallets to other disposal or recycling locations (as haulers would have economic incentive to effectively educate their customers to manage their pallets). Given that current material disposal bans in North Carolina receive little enforcement effort, it is not likely that the pallet ban will differ, and therefore it is not believed a significant gap exists between pallet generation and the pallet reuse/recycling market infrastructure.

As described throughout this section, there are six stakeholders in the pallet and clean wood recycling, reuse, and disposal market which are discussed below:

Landfills;

Generators;

Commercial Haulers;

Scavengers;

Pallet Recyclers;

C&D Processors; and

Clean Wood Markets.

The largest potential negative impact associated with a ban on pallets to MSW landfills would be on the small generator, who would stand to see costs increase when they can no longer place their pallets in their commercial dumpster. This will require these generators to contract with a separate company to collect the pallets, or to rent a second dumpster in which to place pallets. As stated above, it is likely in the absence of strict enforcement, some pallets will continue to be disposed in MSW landfills.

The second largest impact will be on the disposal of broken pallet pieces, off-spec pallets (made of non-conventional materials), and small sized pallets, which can not be repaired, or used to refurbish other pallets. While many of these pallets are already ground, more will now need to be ground and sold – primarily for fuel. The problem is that local boiler fuel users are currently only buying ground clean wood – as opposed to ground wood that includes painted, stained and engineered wood (which boiler fuel buyers in the Northeast purchase).4 Thus, there is limited tolerance for pallets made from engineered wood or painted wood by the grinders, which will require that such wood and pallets will have to go to C&D landfills. 4 Companies burning a mix of green chips and clean waste wood can sell their resulting ash, while companies burning waste wood containing painted, stained and engineered wood would have to landfill the ash, increasing costs.



Even if all pallets destined for MSW landfills (estimated at 445,000 pallets per year) were to be diverted to pallet recyclers, this would still only represent six percent of total pallet recycling capacity in the County, for which sufficient capacity exists at pallet recyclers to handle this material (see Pallet Recyclers below).

The biggest barrier to compliance with a disposal ban lies in the collection costs vis-à-vis the low value of pallets from small quantity generators, off-spec and off-size pallets. Small quantity generators are going to find per-unit costs of hiring a commercial hauler to separately handle their pallets to be high compared to simply throwing the pallets in with MSW, and it is unlikely that the scavengers will be willing to pick up off-spec and off-size pallets because the scavengers are not generally paid for off-size pallets.

Given the legitimate challenges associated with enforcing a pallet ban, and also on the likelihood that a small number of pallets (off-spec or small sized) will continue to be generated by commercial businesses where disposal in the municipal solid waste stream is cost-effective and not abusive of the intent of the ban, it would appear that an allowance for “de minimus” quantities would be reasonable. Note that is, in effect, how the current ban on OCC disposal works, with small generators exempt from the ban. An exemption for de minimus generators and the difficulty of enforcement will reduce the incremental diversion potential of enacting the ban. Given the frequent non-compliance the MSW Team witnessed in the field regarding the County’s cardboard source separation ordinance5 (cardboard is a more valuable and pervasive material), high compliance rates with the pallet ban could not reasonably be expected without rigorous outreach and enforcement. Additional impacts are discussed below.

4.5.1 LANDFILLS MSW landfills would lose tip fee revenues related to the disposal of pallets. Assuming all 445,000 pallets estimated to be going to MSW landfills were eliminated from MSW landfills (an unreasonable assumption) the pallet ban would cause a loss of $445,000 annually based on an average tip fee of $40 per ton. MSW landfill owners were not contacted for this report. However, it is not believed that the quantity of pallets is large enough to have a meaningful impact on MSW landfills from loss of tip fee revenues.

MSW landfills may also incur some additional costs if the ban is aggressively enforced. As with any regulatory action, effectiveness of the pallet ban is expected to be proportional to the degree to which the ban is enforced. If enforced aggressively, such that MSW landfills are at risk of financial or other penalties for non-compliance, MSW landfills may need to take steps to closely monitor incoming deliveries and to develop incremental fees to cover the cost of pallet removal from incoming loads. It is likely, however, that such costs would be passed on to landfill customers.

Conversely, it may be expected that at least some pallets from commercial sources find their way into C&D landfills. This is especially true of businesses that generate loads of mixed inert debris and other wastes that qualify for disposal in C&D landfills.

5 Mecklenburg County has an ordinance requiring businesses that contract for 16 yards/week or more of waste disposal to separate OCC and office paper for recycling.



4.5.2 GENERATORS As shown in the results of our phone and on-site surveys, pallets are widely generated across certain industry types. However, the majority of these pallets (and virtually all pallets generated by the largest entities) are already being backhauled or recycled. Even moderate sized generators, or those generators that generate common sized pallets, stand to receive service from pallet scavengers, reducing the impact of the pallet ban.

Small quantity generators, especially those in industries that do not regularly generate pallets or that generate off-size pallets, would be expected to incur the most negative impact of a ban on pallets to MSW landfills. Although builders of smaller, residential homes were found to generate pallets that could not be diverted, builders and other pallet generators in the construction industry will be largely immune from the ban because their mixed wastes are disposed at C&D landfills, which are not included in the ban.

Our phone and on-site surveys did not attempt to study pallet generation among 13,430 businesses (with only 38,000 employees) deemed to be Unlikely pallet generators. To the extent these businesses generated pallets, it is hypothesized that such generation would be rare and sporadic and is therefore unlikely they would even be aware of a pallet ban. It is assumed that such businesses would incur extra costs for pallet disposal (i.e., they would be required to pay a third party to collect their pallets), but that the incidence of pallet generation among these businesses would minimize the number of times, and therefore the cost, of needing such a service.

On a related note, the pallet ban may also increase friction between small quantity generators and local commercial waste haulers. Haulers generally responded to our survey that a pallet ban at MSW landfills would necessitate their taking steps to keep pallets out of commercial dumpsters, through policy changes and even fines or back-charged to the small business. Such fees may be perceived as unfriendly towards customers at first. However, it is likely that over time any customers that generate pallets would be, out of necessity, informed by their haulers of the limitations of pallet disposal with other commercial refuse.

Another comment that can be made about the generators is that the pallet ban will impact generators of off-spec pallets more so than standard pallets

4.5.3 COMMERCIAL HAULERS Licensed haulers that provide dumpster and roll-off service did not appear to be concerned about the pallet ban. Pallets and clean wood were not reported in either the phone or hauler surveys to be prevalent in commercial waste at the current time, so it appears unlikely that haulers will perceive their enforcement of the ban to be an impact on a wide number of customers. Conversely, such a ban may even drive the need for separate collections, and hence more business, from large pallet generators.

To the extent their customers cannot economically support a separate container for pallet/clean wood collection (or for mixed wastes that can be disposed at a C&D landfill instead of an MSW landfill), haulers indicated that it may be necessary to impose a policy of no pallets. This could lead to friction between haulers and some customers, but it is likely that such friction would dissipate as word of the pallet ban spread (including through communications by the haulers to their customers).



Ultimately, while it cannot be predicted how aggressive haulers would be, we can speculate that it will be in direct proportion to the rigorousness of enforcement of the ban at local landfills. As with any other regulatory action, low priority given to enforcement may undermine the regulation. If the pallet ban is not enforced, or if it is possible to discount the ban by allowing some “de minimus” disposal of pallets, then haulers may simply continue “business as usual” with little to no effect.

4.5.4 SCAVENGERS The pallet scavenging business in Mecklenburg County appears to be functioning effectively at the current time given current market conditions. These scavengers are currently unlicensed, and it was beyond the scope of this project to comment on the pros and cons of an unlicensed scavenging industry. While it was not possible to identify and comprehensively survey from the ranks of pallet scavengers (some of whom do so only recreationally for extra cash and some who have staked out entire businesses on the service), the MSW Team received feedback from several stakeholders that enable us to discuss some potential impacts of a pallet ban.

In general, scavengers exist because of the opportunity to derive incremental revenue from pallets. If pallets were banned, it appears that the scavenging community would be up to the task of absorbing additional pallets that could be sold for recycling. On-site observations, as well as national statistics, suggest that at least half of all pallets would be constructed of sizes that are recoverable within the scavenging community.

However, it is unlikely that scavengers would collect small, damaged, or otherwise off-spec pallets from small generators in the absence of a negotiated agreement with the local business (e.g., they can only take the good pallets if they also take the bad), or unless a market developed for these unwanted pallets (and parts).

In a related matter, it was reported by a number of the pallet recyclers that they would be willing to collect and process these small quantities of unusual sized or broken pallets, but only if they were paid to collect the pallets. Most generators simply find it less costly to throw them into the dumpster than to pay an extra cost (even if it is nominal) for someone to collect their pallets separately. If pallets were banned, it appears that at least some incremental diversion could be achieved, especially if enforcement were aggressive enough to make proper handling of pallets more financially desirable. However, as demonstrated in this study the pallets being disposed already represent a small fraction of the overall number of pallets generated, which suggests decreasing returns.

4.5.5 PALLET RECYCLERS As discussed above, a ban on disposal of pallets at MSW landfills would result on an estimated 445,000 additional pallets requiring alternative recycling or disposal. Based on discussions with pallet recyclers, wood grinding operations, and mulch producers, sufficient capacity exists to handle all of these pallets.

In fact, interviews with the pallet recyclers indicate that there is significant demand for rebuilt/recycled pallets, and that the demand exists for increasing the quantity of pallets collected for recycling. None of the pallet recyclers interviewed felt that a ban on pallets to landfill would have a negative impact on them.



However, on-site observation suggest that some fraction of these pallets could not be reused because of their size and/or condition. Even if every pallet could be collected and delivered to a remanufacturer, some discard would be inevitable. National statistics show that roughly five percent of all pallets are chipped for these reasons.

As stated above, it is not reasonable to assume that a ban on pallets to MSW landfills will result in 100 percent diversion of these pallets. Some percentage will still end up at MSW landfills, some will move to C&D landfills, some to pallet recyclers, and some percent to pallet grinding operations. A rough estimate might be that 50 percent of the 445,000 pallets estimated to be landfilled at MSW landfills now would end up being delivered to pallet recyclers, either for recycling or grinding. This would require the existing pallet recycling infrastructure to handle roughly 225,000 more pallets per year, or less then four percent of the current pallet recycling infrastructure. This would not present a problem for the pallet recyclers, although it would increase the pressure on the grinders to find new markets for the additional ground material (see below).

4.5.6 C&D PROCESSORS At the current time, there is no high volume, large-scale facility in Mecklenburg County where mixed loads of C&D waste are processed and sorted, with various materials recovered prior to disposal.6 The quantity of clean wood and other potentially recyclable materials in C&D waste suggest that establishment of C&D processing would greatly increase recovery. However, of equal importance, establishment of C&D processing capacity involves capital investment and increased operating costs that must be considered within the local disposal and recycled material market dynamics. While it was beyond the scope of this project to develop a County-specific solution for C&D processing infrastructure that would indubitably increase recycling of clean wood as well as other C&D materials, experiences with C&D recovery in other geographic markets and under other regulatory conditions across the nation suggest certain important boundaries for such projects. The following three case studies are provided as background.

4.5.6.1 Massachusetts Case Study The state of Massachusetts implemented a ban on the landfilling of unprocessed C&D waste three years ago. At the current time, there are 15 C&D processors now taking Massachusetts C&D waste, both in the state and in surrounding states. Based on on-site surveys conducted by Project Team member DSM at all of these processors, actual recovery rates for clean wood are significantly lower than might be intuitively expected. On average, only 20 percent of the clean wood generated in Massachusetts was recovered as clean wood and only 50 percent of painted, stained, and engineered wood was recovered for boiler fuel. In total, only 27 percent of all C&D wood was recovered in Massachusetts for beneficial use, with the remainder being landfilled (either as fines or as ground C&D). Notably, this recovery cost roughly $75 to $85 per ton net of the sale of the material.

6 However, there are several warehouse-type facilities that utilize manual floor sorting of certain loads of mixed C&D waste to achieve diversion of some recyclables to meet LEED certification. These facilities do not target all mixed C&D waste and are not considered to be mixed C&D waste processing facilities of the type found in other regions of the country (to which this section refers).



The primary problem in Massachusetts associated with recovering clean wood is that once clean wood ages, it looks like aged pressure treated or stained wood. This can be seen in Figure 4-9.

Figure 4-9 Recovered Wood from C&D Processing Plant (Massachusetts)

Because most clean wood applications have very low tolerances for painted, stained and especially pressure treated wood, sorters must err on the side of caution and let much clean wood go as potential painted or stained wood. The only way to increase the recovery of clean wood would be to source separate it. However, very little source separation was occurring in Massachusetts because of the added cost of separate containers, combined with confusion as to what could be placed in the source separated container (see the above comments from the builders for a discussion of similar concerns in Mecklenburg County).

4.5.6.2 California Case Study California’s Integrated Waste Management Act (Assembly Bill or AB 939) requires municipalities throughout the state to achieve a minimum 50 percent diversion rate. This applies to the overall waste stream, including both municipal solid wastes and C&D debris. Not surprisingly, C&D processing facilities have become an integral part of the recycling infrastructure in California, especially in the urban/suburban areas where construction activity is high.

As might be expected, AB 939 establishes a range of definitions for what activities constitute allowable diversion of materials for state reporting purposes. Of particular interest, the state



considers post-processed, ground C&D debris used as landfill alternate daily cover (ADC) to be included in the calculations for total diversion. Available data suggests that California C&D processors recover anywhere between 20 and 90 percent of their C&D debris. However, for those facilities reporting high diversion rates, post-processed C&D and fines used for ADC make up half or more of the recovered amount. In total, California municipalities received recycling credit for 383,000 tons of post-processed C&D waste disposed in landfills in 2006.

It must also be noted that disposal tip fees in most of California’s more densely populated areas range frequently exceed $75 per ton. In more rural areas of the state, where disposal tip fees are lower, C&D processing facilities have not been developed.

4.5.6.3 South Florida Case Study The Miami-Dade Department of Solid Waste Management operates a network of six waste transfer and disposal facilities to serve its 300,000 households in a highly urbanized area. Miami-Dade has established waste-to-energy (WTE) as its primary waste disposal strategy. WTE facilities have many benefits, among them the energy recovery from and volume reduction of wastes prior to final disposal of ash. However, WTE facilities cannot process large quantities of C&D debris due to the bulky, heavy, non-combustible materials such concrete and metals. C&D debris therefore must bypass the WTE and find another outlet for disposal. At the current time, there are no regulatory requirements for C&D processing in Florida or Miami-Dade County.

However, because of the dearth of disposal capacity in Miami-Dade for C&D debris (which cannot be processed at the County’s WTE and therefore includes higher transportation costs because there are no local C&D landfills with attractive tip fees), tip fees for C&D disposal have begun to exceed $80 per ton. While new disposal facilities are extremely difficult, if not impossible, to permit, the state of Florida permits recycling facilities more readily. The high C&D disposal tip fees and more lenient recycling facility permitting process have lead to the establishment of erstwhile C&D recovery operations within the County by local entrepreneurs.

Based on local research conducted by Project Team member MSW Consultants, these C&D recyclers are primarily pulling only the cleanest, easiest to divert materials prior to densification and long-range transportation of the C&D debris for disposal. Concrete, metals, some OCC and some clean wood is removed for recovery, although diversion rates were anecdotally reported to be less than 20 percent of total C&D. In practice, the C&D recovery operations in South Florida were found to primarily be densifying the debris for more economical long haul transport of the debris to lower cost landfills that were located between 30 and 200 miles distant. Recovered recyclables represented a slight boost because of the reduced transportation and disposal cost, as well as incremental material revenues, but were not the primary objective of the operations.

4.5.6.4 C&D Recycling Ordinances/Permit Requirements One final strategy for encouraging C&D diversion warrants mention. Some jurisdictions have implemented local ordinances that require builders to be responsible for C&D diversion from their job sites. There are several strategies contained in such ordinances, including developing a C&D diversion plan as part of their application for receiving a building permit, or requiring pre-payment towards C&D recovery with a refund issued only after diversion has been



documented. Such ordinances may require builders to document the waste generation and diversion management practices on a job-by-job basis.

Although such ordinances necessarily create more paperwork and therefore increase the cost of building and renovation projects, they have been successful in many jurisdictions when approval of the permit is tied to compliance with submission of and execution of the C&D recycling plan. It should be noted that such aggressive local ordinances have primarily been implemented in geographic regions where C&D processing facilities exist to manage the stream of recycled material-rich loads of C&D debris that are generated as a result of such a plan.

4.5.6.5 Summary The Project Team notes several recurring themes among these C&D processing case studies. First, two of the three case studies are driven by state regulation requiring either C&D processing or else mandated diversion rates. Second, disposal tip fees in all three cases are at or above the $75 per ton range. This is important because it establishes the opportunity cost of simply disposing of C&D without processing. Third, recovery rates of C&D materials, excluding ground C&D and/or fines coming off the end of the processing line, are well below 50 percent, and in many cases closer to 20 or 30 percent (or lower).

Based on the Project Team’s experience with these C&D processing case studies, it is believed that actual clean wood recovery from C&D processing in Mecklenburg County would be closer to the 20 percent range (as in Massachusetts) of all clean wood in the C&D waste stream if the County were to pursue a strategy of high-tech processing of all (or most) C&D waste. Further, the cost to divert this material via high-capital-investment C&D processing facilities, such as those described in the case studies above, would be close to double the current local disposal rates available in the County.

In the near term, the low-tech floor sorting operations for C&D that have been established in the County to remove concrete, block, metals, drywall and some wood (and possibly other materials) from selected C&D loads that are rich in these materials should continue to develop at a pace dictated by the local market (which is currently driven primarily by LEED recycling requirements for commercial construction projects). It is hypothesized that the establishment of both high-tech C&D processing infrastructure and the associated costs to be imposed on the private building and hauling community in Mecklenburg County to require them to use such a higher cost disposal option would be more challenging.

4.5.7 CLEAN WOOD MARKETS A ban on disposal of pallets at MSW landfills, if strictly enforced, would take up most of the remaining existing recycling capacity for ground clean wood. If the ban were extended to clean wood, significant additional capacity would need to be developed for ground wood. Potential markets include:

New bio-fuel boiler demand;

Wood pellets;

Erosion control fabric;

Particle Board; and



Mulch.

These are discussed below.

4.5.7.1 Bio-Fuel Demand The demand for waste wood for boiler fuel is driven primarily by the higher BTU value of the waste wood when compared to green chips (7,380 BTU/lb for waste wood compared with 4,500 BTU/lb for green chips7) coupled with a lower price for the waste wood. That means that a buyer for a biomass boiler can purchase roughly 40 percent fewer tons of wood waste than green chips to supply the same amount of heat value to the boiler. This, when combined with a price per ton for waste wood which is reported to be about one-half of that for green chips means that a ton of waste wood is roughly 80 to 90 percent cheaper per BTU than a green chip.

At the time that this study was undertaken, owners of bio fuel boilers were only taking ground clean wood – not ground painted, stained or engineered wood. And, the existing bio-fuel boilers were all at capacity. Therefore, pushing significant new quantities of clean wood out of landfills would require that either new bio-fuel combustion facilities be constructed, or that other uses for ground clean wood be developed.

As stated above, Steve Elliot of Compost Central believes that he can increase the sale of colored mulch to free up another 2,500 tons of bio-fuel capacity, but that is less then five percent of the total estimated clean wood going to C&D landfills.

4.5.7.2 Wood Pellets Wood pellet manufacturers can afford to pay more than boiler operators for clean wood. However, because they are extruding the wood through a pelletizer, they require a very clean wood with no metal or other contaminants. They also can not accept anything other than clean wood, which restricts grinders from grinding pallets or other clean wood that might contain particle board, plywood, or oriented strand board. Experience in the Northeast suggests that wood pellet manufacturers cannot use ground waste wood on a consistent basis because of these limitations.

4.5.7.3 Erosion Control Fabrics One of the wood waste grinders had been sending ground wood to a firm producing erosion control fabric. They paid a premium compared to ground wood sold for boiler fuel. However, they also required a cleaner material. As of the date of the interview the firm had switched to waste Cyprus wood and was no longer purchasing ground waste wood.

4.5.7.4 Particle Board Tafisa in Lac-Megantic, Quebec is the largest particle board production plant in North America. Tafisa is currently in the final stages of construction of a new line which will have the capability to utilize up to 40 percent waste wood in the production of particle board. If start-up goes as planned, Tafisa believes that it will eventually have the capability to utilize up to 275,000 tons per year of waste wood.

7 University of New Hampshire Life-Cycle Assessment of C&D Derived Biomass/Wood Waste Management, September 7, 2007.



While it is unlikely that wood waste grinders in North Carolina will be able to ship waste wood to Quebec economically, if Tafisa is successful additional capacity closer to Mecklenburg County could be constructed. Even if this were the case, however, it would be years away given the development time for such a facility.

4.5.7.5 Mulch Mecklenburg County has recently completed a study of the potential demand for mulch and compost. While that study has not been made available, an internal draft indicated that there was significant potential demand for additional mulch, compost (which uses ground wood as a carbon source) and for the residential construction industry (which applies the material around the completed foundation of a new house to prevent mud from splattering on the foundation).

As discussed above, Compost Central believes that it can double the amount of ground wood sold as mulch, and that it can also increase sales of compost, and therefore use of ground wood. Other local grinders indicate capacity for more clean wood. These uses would absorb 12,500 tons of clean wood, which would be sufficient to manage increases resulting from a strictly enforced pallet ban. However, greater increases in the market for mulch may not be as readily available in Mecklenburg County, and it is doubtful that the currently disposed quantities of clean wood could be converted into mulch and beneficially used.

4.6. CONCLUSION

The issue of pallet and clean wood recovery in Mecklenburg County appears to be one of short and long-term considerations. The County is already home to a developed pallet recycling industry, and our studies suggest that not only are over 87 percent of all pallets already recycled or otherwise beneficially reused in Mecklenburg County, but the current pallet recycling infrastructure, as well as the impending expansion to the local uses for clean wood, is sufficient to absorb the 445,000 pallets (11,128 tons) that are estimated to be disposed in MSW landfills (for either reuse or grinding for fuel, mulch, or other purposes). Collection/recycling costs and enforceability of the ban for small quantity and off-size/off-spec pallet generators are the limiting factors to closing the gap and eliminating disposal of pallets in MSW landfills.

Longer term, any meaningful initiatives to capture the large fraction of clean wood that is currently being disposed, especially in C&D landfills as a result of construction activities, would need to occur hand in hand with growth in new markets for use of the clean wood. Our best estimate is that the establishment of C&D processing to recover clean wood, as well as associated regulations that would compel use of such a facility despite lower-cost local disposal options, would result in an additional 13,000 tons of clean wood being separated for recycling. Combined with the ban on disposal of pallets in MSW landfills, the end result would be that roughly 11,000 tons of new demand would have to be created in the County for clean wood. As discussed above, this would have to either involve the development of new bio-fuel combustion capacity and/or a significant increase in the demand for compost and colored mulch.


5. OTHER TARGETED MATERIALS

5.1. INTRODUCTION

Although the primary focus of this project was on wood pallets and clean wood, it was economical to gather information on several other materials in conjunction with the pallet/clean wood research. This section summarizes the data and information gathered for the following materials:

Old Corrugated Cardboard (OCC) in the commercial waste stream;

Plastic Films in the commercial and C&D waste streams;

Gypsum Wallboard in the C&D waste stream;

Vinyl Siding in the C&D waste stream; and

Asphalt Shingles in the C&D waste stream.

Throughout this section, it is important to note that the Likely and Possible Generators were defined strictly in terms of wood pallet and clean wood research. No attempt was made to broaden our research to representatively capture generation across the entire commercial waste stream for the materials in this section. Consequently, we have not attempted to derive the total quantity of these materials in the commercial waste stream. Further, based on our review of phone survey responses compared to on-site survey responses for the Likely Generators, the MSW Team does not believe the phone survey-derived generation and recycling rates from Possible Generators can be relied upon to reflect the incidence of OCC and Plastic Film in the commercial sector. For this reason, only the results of the on-site surveys of commercial generators are shown.



5.2. OLD CORRUGATED CARDBOARD

5.2.1 GENERATION AND RECYCLING IN COMMERCIAL WASTE Old corrugated cardboard is broadly generated across the commercial sector. The MSW Team was able to collect data on OCC generation, recycling, and disposal as part of its phone and on-site surveys. Table 5-1 summarizes the percentage of respondents to both the telephone and on-site surveys of the Likely pallet/wood generators that reported or were found to generate OCC.

Table 5-1 Surveys of OCC Generation Among Likely Pallet/Clean Wood Generators


NAICS Code

Industry Surveyed Generate OCC

Percent Surveyed Generate OCC

Percent

31-33 Manufacturing 31 12 51.6% 55 39 71%

42 Wholesale Trade 62 32 62.9% 95 60 63%

44-45 Retail Trade 42 22 64.3% 82 52 63%

48-49 Transportation/Warehousing 17 4 35.3% 21 5 24%

56 Admin/Support/Waste Mgmt

3 1 100.0%

3 2 67%

62 Health Care 3 1 66.7% 6 3 50%

71 Arts/Recreation 3 1 66.7% 3 3 100%

Total 161 73 59.0% 275 164 62%

Interestingly, the phone and on-site surveys reflect similar incidence of OCC generation within the same universe of Likely Generators.

Based on the on-site survey responses, the MSW team calculated the OCC generation coefficients for each industry group for which a sufficient number of samples were obtained. Generator coefficients are stated in terms of the number of pounds of OCC per employee per year, and were calculated based on the weighted average generation rate at each of the businesses surveyed.

On-site surveys enjoy the benefit of having a knowledgeable recycling professional quantify the OCC based on direct visual observation. Not only can the on-site surveyor ask questions, but can subsequently (with cooperative businesses) explore the answers to clarify and improve accuracy. For this reason, on-site surveys are believed by the MSW Team to reflect the most accurate portrayal of OCC generation, recycling and disposal. Table 5-2 shows the OCC generation coefficients derived from over 280 on-site surveys of Mecklenburg County businesses.



Table 5-2 OCC Generator Coefficients Based on On-site Surveys of Likely Pallet Generators (lbs/employee/year)

NAICS Code

Industry Total Generation

Disposed Recycled Percent Recycled

31-33 Manufacturing 874 51 823 94.2%

42 Wholesale Trade 887 224 663 74.7%

44-45 Retail Trade 3,260 300 2,960 90.8%

48-49 Transportation/Warehousing 284 64 220 77.5%

56 Admin/Support/Waste Mgmt 867

0 867 100.0%

62 Health Care [1] 26 26 0 0.0%

71 Arts/Recreation 1,664 104 1,560 93.8%

[1] Data from the health care sector are from too small a sample to be significant.

Table 5-3 applies the OCC generator coefficients to the known employment within each industry group to calculate the quantity of OCC generated in each stratum of businesses among Likely Generators.

Table 5-3 OCC Generation among Likely Pallet Generators Based on On-site Surveys (tons)

NAICS Code



31-33 Manufacturing 34,235 892 14,382 15,274

42 Wholesale Trade 29,169 3,335 9,868 13,203

44-45 Retail Trade 25,193 4,063 40,090 44,153

48-49 Transportation/Warehousing 15,145 489 1,681 2,170

56 Admin/Support/Waste Mgmt 5,292 0 2,312 2,312

62 Health Care 13,624 178 0 178

71 Arts/Recreation 4,171 229 3,423 3,652

Total 122,658 9,186 71,758 80,942

Likely pallet/wood generators generated a significant amount of OCC with the vast majority being recycled. This is not surprising in light of the current market prices for recovered OCC, the existing landfill disposal ban for OCC generated from larger businesses,1 and County outreach to businesses. However it is interesting to note that the recycling rate (estimated to average 89% over the seven sectors) is only two percentage points higher than the current estimated recycling rate for pallets (without a landfill ban)..

1 Defined to include any commercial entity that generates more than 16 cubic yards of waste per week or more than 500 pounds per month of office paper and OCC combined.



5.2.2 RECYCLING MARKET INFRASTRUCTURE There are ample markets for OCC available in Mecklenburg County. The primary limitation is the cost of keeping OCC separate, storing until there is a sufficient quantity for recycling, and arranging for a firm to collect the material. It is not unusual for hauling firms to charge a rental fee for the OCC container, and charge for pickup. These charges often reduce the economic incentive to recycle OCC, especially when there are relatively low landfill costs as is the case in Mecklenburg County. However, the County does have a program where they will provide free containers for small generators, reducing one of the impediments to recycling.

It is also interesting to note that along with a large pallet scavenging community, there are informal collectors of OCC – sometimes in conjunction with pallets, but often a separate entity with a panel van or box truck. This significantly increases the ability of small generators to set aside OCC for recycling without incurring the cost of dumpster rental.

Given current markets for OCC it is our opinion that recycling of OCC will remain viable for all but the smallest businesses given regulatory requirements to recycle OCC. OCC prices have been high (currently averaging roughly $120 per ton for baled OCC), but even in periods of low demand OCC still has significant value (the low over the past five years has been $60 per ton, and the average has been closer to $100 per ton.

5.3. FILM PLASTIC

Film plastic was analyzed in both the commercial and C&D waste streams.

5.3.1 GENERATION AND RECYCLING IN COMMERCIAL WASTE Results of the phone and on-site surveys for plastic film generation among both the Likely and the Possible pallet/wood generators are shown in Table 5-4.

Table 5-4 Generation of Film Plastic Among Likely Pallet/Wood Generators


NAICS Code

Industry Surveyed Generate Film

Percent Surveyed Generate Film

Percent

31-33 Manufacturing 31 6 19.4% 55 21 38%

42 Wholesale Trade 62 15 24.2% 95 39 41%

44-45 Retail Trade 42 13 31.0% 82 33 40%

48-49 Transportation/Warehousing 17 4 23.5% 21 5 24%

56 Admin/Support/Waste Mgmt 3 0 0.0% 3 1 33%

62 Health Care 3 2 66.7% 6 0 0%

71 Arts/Recreation 3 0 0.0% 3 0 0%

Total 161 40 24.8% 275 99 37%

Consistent with results for other materials, the on-site surveys reflect a significantly higher incidence of film plastic generation within the same universe of Likely Generators compared



to the phone survey. This confirms the MSW Team’s belief that on-site surveyors can better quantify film plastic generating activities and related management.

Table 5-5 shows the film plastic generation coefficients derived from over 280 on-site surveys of Mecklenburg County businesses. Table 5-5 Film Plastic Generator Coefficients from Likely Pallet Generators Based on On-site Surveys

(lbs/employee/year)

NAICS Code

Industry Disposed Recycled Total Generation

31-33 Manufacturing 78 0 78

42 Wholesale Trade 33 22 55

44-45 Retail Trade 125 3 128

48-49 Transportation/Warehousing 124 0 124

56 Admin/Support/Waste Mgmt 26 0 26

62 Health Care 0 0 0

71 Arts/Recreation 0 0 0

Table 5-6 applies the film plastic generator coefficients to the known employment within each industry group to calculate the quantity of film generated within each stratum of Likely Generators.

Table 5-6 Film Plastic Generation from Likely Pallet Generators Based on On-site Surveys (tons)

NAICS Code



31-33 Manufacturing 7,648 126 84 210

42 Wholesale Trade 9,145 572 14 585

44-45 Retail Trade 46,397 2,877 0 2,877

48-49 Transportation/Warehousing 4,808 63 0 63

56 Admin/Support/Waste Mgmt 18,413 0 0 0

62 Health Care 26,038 0 0 0

71 Arts/Recreation 4,016 0 0 0

Total Film Plastic 116,465 3,637 98 3,735

As shown, relatively little film plastic (roughly two percent) appears to be getting recycled by the businesses visited as part of the on-site surveys. This is not unusual because of the high volume and low density of film which makes it difficult to store and transport at reasonable cost. Only in the case where balers are available and there is a large volume of a homogeneous clean film will it be economical to recycle the plastic film. This is the case despite its relatively high value (currently ranging from $600 to $800 per ton for truck load bales). That is why the majority of recycling was reported by the manufacturing and wholesale trade sectors.



5.3.2 DISPOSAL IN C&D WASTE STREAM Table 5-7 summarizes the estimated quantity of film plastic found in the C&D waste stream. The table shows the average, or “best estimate,” as well as the lower and upper confidence intervals at a 90 percent level of confidence. This means that we can be 90 percent sure that the true quantity of film plastic lies within the lower and upper bounds shown in the table.

Table 5-7 Film Plastic in C&D Waste Stream


Tons of Film Plastic

Minimum (90%) 0.2% 926

Average 0.3% 1,283

Maximum (90%) 0.4% 1,640


5.3.3 RECYCLING MARKET INFRASTRUCTURE Based on prior experience, the MSW Team is aware that film is widely recyclable under the conditions that it is clean and can be aggregated economically through backhaul. We offer the following observations based on our prior experience, discussions with a local recycler, and based on feedback received from the builder focus groups conducted for this project.

In the commercial sector, film plastic recycling takes place (as supported in the research to this project) at establishments where retail bags and shrink wrap (usually either HDPE, LDPE, or linear LDPE) are used on site or else returned by customers in a large enough volume to support separation, densification, and backhaul of the material. Retail bag recycling is offered by many grocery and home improvement stores, and indeed there are many states and jurisdictions that are actively considering taking action to improve recycling (by requiring on-site take-back programs) or to limit or ban the use of retail bags.

In the C&D sector, the focus groups with builders indicated that none of the builders who attended the focus groups were currently recycling film. This is consistent with the behavior of construction firms in other areas of the country.

Ultimately, there are two primary reasons for low recycling of film plastic. First, film is a relatively small part of the overall commercial and construction waste stream. Most commercial waste characterization studies vastly overestimate the actual weight of disposed film, simply because they do not correct for moisture and particulate contamination. A 2005 study by New York City found that over two-thirds of the unadjusted weight of disposed film plastic (in the residential waste stream) was actually moisture and particle contamination. And according to the Mecklenburg County C&D waste characterization study, plastic film makes up only 0.3 percent of C&D on a weight basis. Second, while markets for clean PE film exist throughout North America, there are limitations to the ability of commercial businesses, municipal collection programs, recycling facilities, and construction companies to recycle films because of the following constraints:

Contamination: The high surface volume to weight ratio allows for significant contamination from dirt, grit, water, and organic matter. It is not unusual for dirt and



water on the film to weigh more than the PE film once it has been used for most applications.

Collection and transportation: Film is typically recycled by commercial and industrial establishments that either have a baler for collection and storage of film, or have access to relatively low backhaul costs to a central distributor with baling capabilities. This is not the case for smaller commercial establishments or for construction firms. As a consequence it is difficult to design a system that the vast majority of businesses and construction firms can use to store and transport film economically – especially given the relatively limited quantities generated by these establishments at any given time.

Mixed films: Especially construction firms tend to generate a mix of films. Some of the film is clear PE film, which has value, but a significant amount of the film in the construction industry consists of the blue tarps. These films cannot be mixed with clear PE film, making it even more difficult for construction firms to collect, store and transport film for recycling.

MSW Team member DSM is an American Plastics Council Technical Assistance Program provider for the Northeast, and has been working to increase plastic film recycling for the past ten years. Specifications for accepting plastic film vary but generally restrict moisture and dirt contamination, as well as restrict the mixing of resins. However each processor has different specifications and conditions for acceptance based on their capacity to wash, and the markets to which they are selling. As state above, typical plastic film sent for disposal may average two-thirds of the weight as moisture and dirt. This is not acceptable for recycling in most cases. That is why the manufacturing and wholesale sectors are most likely to recycle plastic film – because it is typically homogenous, generated in sufficient quantities, and can be kept dry and relatively contaminant-free. None of these circumstances exist in the construction industry. As such, it is unlikely that plastic film will be recycled by the construction industry given all of the other materials that they can recycle first that weigh more and have less limitations on moisture and contamination.

5.4. VINYL SIDING

Vinyl siding was evaluated only in the C&D waste stream (but not in commercial waste).

5.4.1 DISPOSAL IN C&D WASTE STREAM Table 5-8 summarizes the estimated quantity of vinyl siding found in the C&D waste stream. The table shows the average, or “best estimate,” as well as the lower and upper confidence intervals at a 90 percent level of confidence. This means that we can be 90 percent sure that the true quantity of vinyl siding lies within the lower and upper bounds shown in the table.

Table 5-8 Vinyl Siding in C&D Waste Stream


Tons

Minimum (90%) 0.02% 70

Average 0.05% 194

Maximum (90%) 0.08% 318




Very little vinyl siding was found in the disposed C&D waste stream.

5.4.2 RECYCLING MARKET INFRASTRUCTURE Approximately 6 percent of the vinyl siding is disposed of at a typical construction site. This material is typically clean and readily recyclable if it can be kept separate from other waste materials and cost effectively transported to a vinyl recycler.

None of the builders who attended the two focus groups were currently recycling vinyl siding. The MSW Team did, however, contact all of the potential vinyl recyclers listed in Mecklenburg County’s Resource Guide, as well as two companies suggested by the Vinyl Recycling Institute to determine the potential demand and specification for vinyl siding scrap.

In general, none of the vinyl recyclers in Mecklenburg are taking vinyl siding scrap. Most reported that they concentrate on clean industrial scrap and had limited capability to clean vinyl siding from construction job sites.

The only regional vinyl recycler who is currently accepting vinyl siding from construction sites is Reily Recovery in Chapel Hill. Kevin Reily has been involved in vinyl siding recycling since 1996, and is one of the innovators in this field. Mr. Reily reported that they will provide containers to job sites in areas near Chapel Hill for a fee of $20. They will collect the containers at no cost and process the material provided that it is relatively free of dirt and contamination. Their containers are typically four cubic yard containers (7’x4’x4’) and can be loaded with roughly 800 pounds of vinyl siding if the siding is stacked in the containers. Mr. Reily reported that he would need to collect a full truck load of containers if he were to collect material from Mecklenburg County.

Harmony Industries, in High Point, NC currently does not recycle vinyl siding. However, David Pendlebury reported that they would be willing to purchase vinyl siding for 5 cents per pound provided it were delivered in minimum load sizes of 5,000 to 10,000 pounds, and that contamination was minimal.

Finally, Custom Polymers of Charlotte reported that while they currently do not take vinyl siding, they would be willing to consider accepting the material if it were clean and baled.

In conclusion, while vinyl siding recycling is currently not occurring in Mecklenburg County, the potential exists for development of a vinyl siding recycling infrastructure. It is likely that it would require active involvement by the County in establishment of a central collection, inspection/cleaning, and densification location. Markets for the collected material would then appear to be readily available.

5.5. GYPSUM DRYWALL

5.5.1 DISPOSAL IN C&D WASTE STREAM Table 5-9 summarizes the estimated quantity of gypsum drywall found in the C&D waste stream. The table shows the average, or “best estimate,” as well as the lower and upper confidence intervals at a 90 percent level of confidence. This means that we can be 90



percent sure that the true quantity of gypsum drywall lies within the lower and upper bounds shown in the table. Both unpainted and painted gypsum are shown

Table 5-9 Gypsum Drywall in C&D Waste Stream

Unpainted Gypsum Painted Gypsum


Tons Percent of C&D Waste

Tons

Minimum (90%) 5.0% 18,819 0.1% 448

Average 6.8% 25,806 0.4% 1,613

Maximum (90%) 8.7% 32,793 0.7% 2,778


As shown, the vast majority of drywall disposed in C&D landfills in Mecklenburg County is unpainted. This follows from the largely new construction market in the Mecklenburg region. Over time, as the County gets built out and development slows, painted drywall resulting from renovation and demolition will begin to increase.

5.5.2 RECYCLING MARKET INFRASTRUCTURE Gypsum has become a significant issue associated with the recovery and disposal of C&D wastes. According to GreenYes Archives, March 2006, “Gypsum has been identified as a leading contributor of hydrogen sulphides (H2S) production in landfills where it is disposed. H2S is produced in a landfill when sulfur compounds decompose in the presence of moisture and absence of oxygen. Under anaerobic conditions, sulfate reducing bacteria produce H2S from the sulfate (SO4

2-) in gypsum and the organic carbon waste materials…” H2S is both an odor issue (it is typically one of the primary odors that people associate with methane production at landfills, although methane is odorless) and a public health issue (Ohio has had to evacuate neighbors to a C&D landfill associated with high levels of H2S, and the U.S. EPA has regulatory thresholds for H2S emissions at landfills).

The issue of H2S emissions from landfills has grown significantly with the grinding of C&D waste for use as alternative daily cover (ADC), and with the landfilling of fines from the grinding and processing of C&D wastes. This is because gypsum wallboard is friable and breaks into small pieces easily when ground or crushed with C&D materials. The resulting gypsum ends up mixed with small pieces of wood (organics) which is the second ingredient needed by the sulfate reducing bacteria. The final ingredients are water and anaerobic conditions, both of which are present in abundance in eastern landfills.

H2S is not only an aesthetic issue. In higher concentrations it can be a health hazard, both to workers on the landfill, and even to surrounding residences. The U.S. EPA was forced to take corrective action against the Regus Industries landfill in Warren, Ohio due to hazardous levels of H2S migrating off-site to neighboring residences. This landfill accepted ground C&D materials (in violation of Ohio EPA regulations), and landfilling was occurring below the water table.

Gypsum can be recovered for recycling. Most common uses include:

Recycling to new gypsum wallboard;



Land application as a soil amendment (especially in high clay content soils where crusting is an issue);

As an additive to compost; and,

In cement production as an additive to stucco or gunite.

Potential uses include:

In flea powder;

Mushroom compost;

As a bulking agent or sludge drying compound;

As a flocculating agent in water treatment; and

As an oil and grease absorber

Paper, which represents between 10 and 15 percent of the gypsum wallboard, can also be recovered and used as animal bedding and/or pelletized for fuel pellets.

Mecklenburg County is fortunate to have one of the innovators in gypsum recycling located nearby. Union Gypsum is currently recycling 80 tons of gypsum per day and expects to increase that to 140 tons per day over the next several years as they develop additional markets for the ground material. Union Gypsum’s primary criteria is that the gypsum be kept separate from other construction materials, be dry, and not be contaminated by paint or wallpaper.

However, there are a number of issues associated with gypsum recycling which limit its success. First and foremost is that it is extremely difficult to recover gypsum once it has been mixed with other C&D wastes. It simply breaks too easily and disintegrates during handling of the C&D materials. Second, while there are a number of uses for clean gypsum, the number of uses associated with painted or wallpapered gypsum is significantly less.

Third, and most importantly, gypsum is a relatively low cost material. The cost of mined gypsum delivered to a wallboard manufacturing plant is roughly $10 per ton. More importantly, sulfur dioxide controls (flue gas desulphurization or FGD) on coal fired power plants results in a perfect gypsum slurry for use in gypsum wallboard manufacturing. Thus, a number of new gypsum wallboard plants are being constructed adjacent to coal fired power plants, where the gypsum slurry can be obtained for roughly one-half of the cost of mined gypsum and the gypsum has already been calcinated during the coal combustion.

At these low costs for the raw material associated with gypsum wallboard production, it is difficult to keep gypsum separate, crush it, remove the paper, and deliver the resulting material to a gypsum wallboard plant for a cost that is competitive with new gypsum. It has been reported to DSM that the maximum distance that recycled gypsum can be transported is roughly 30 miles before the transport cost alone makes recycling non-competitive. Thus, it is likely that significant quantities of gypsum will be recycled only if gypsum is not allowed in landfills due to H2S issues.



5.6. ASPHALT ROOFING

5.6.1 DISPOSAL IN C&D WASTE STREAM Table 5-10 summarizes the estimated quantity of asphalt roofing found in the C&D waste stream. The table shows the average, or “best estimate,” as well as the lower and upper confidence intervals at a 90 percent level of confidence. This means that we can be 90 percent sure that the true quantity of asphalt roofing lies within the lower and upper bounds shown in the table.

Table 5-10 Asphalt Roofing in C&D Waste Stream


Tons

Minimum (90%) 4.8% 16,596

Average 6.4% 24,084

Maximum (90%) 8.4% 31,571


Asphalt roofing was found to make up a significant portion of C&D waste. However, as shown by the relatively wide confidence intervals, asphalt roofing material is not widely dispersed among incoming loads but rather is contained in large quantities in a subset of all C&D loads.

5.6.2 RECYCLING MARKET INFRASTRUCTURE The MSW Team made several attempts to contact local asphalt roofing recyclers during the course of the project. These phone calls to potential asphalt roofing recyclers serving Mecklenburg County were not returned. However, as noted in the discussion of the builder focus groups, none of the builders were recycling asphalt shingles in Mecklenburg County, which would indicate that there is currently not a viable asphalt shingle recycling program.

This is an area where effort by the County could yield additional recycling for four reasons:

1. Asphalt shingles are often already, as reported above, delivered separately to landfills (or with a small amount of wood and plastic contamination).

2. Asphalt shingles (unlike plastic film) are heavy and therefore more expensive to dispose of than light weight materials.

3. Recycled asphalt shingles (RAS) “contain ingredients that hot mix asphalt producers purchase to enhance their paving mixtures including: asphalt cement (or AC binder) and mineral aggregate. Asphalt shingles also contain a fibrous mat made from organic felt (cellulose) or fiberglass that can also be valuable as fiber in some paving mixes.”2

2 Recycling Tear-Off Asphalt Shingles: Best Practices Guide, Construction Materials Recycling Association, October 11, 2007. Data on asphalt shingle recycling contained in this section is excerpted from this guide which was funded in part by the U.S. Environmental Protection Agency.



4. Eight states (including South Carolina) already have a Department of Transportation specification for use of RAS in hot mix asphalt (typically at a maximum rate of five percent of the asphalt). As such, significant data already exist on the use of RAS in hot mix asphalt.

In addition to use in asphalt paving, other potential markets3 include:

Cement kilns;

Coal-fired power plants;

Shingle-to-shingle recycling;

A supplement for road base and sub-base; and

Cold patch.

There are essentially three primary obstacles that would have to be overcome for Mecklenburg County to drive an asphalt recycling program forward. First, the County would need to work with existing hot mix asphalt producers to develop specifications for the RAS. Because of the large amount of work that has already gone on in this area, as well in the use of recycled asphalt paving (RAP) in new hot mix asphalt, this would primarily be a case of providing data on existing specifications and research. For example, the American Association of State Highway and Transportation Officials published a new provisional specification and recommended practice for shingle recycling into hot mix asphalt in December, 2005.4

MSW Team member DSM learned in Delaware that the hot mix asphalt paving producers are anxious to reduce their input costs and are typically prepared to use recycled material in lower specification applications, such as parking lots first, and then move to base course applications, and then finally to County and State road applications as the Departments of Transportation become comfortable with the specifications.

Second, an asphalt grinding location would have to be established where asphalt roofing companies could deliver source separated asphalt shingles. A key issue would be to price the grinding below the landfill cost. This would require an economic analysis of the cost of grinding and transport to the hot mix asphalt producer, minus the value of the ground material which will typically replace virgin asphalt cement.

Third, and most importantly, the County would need to develop a procedure for dealing with the lingering issue of asbestos contamination. U.S. manufacturers discontinued the use of asbestos asphalt shingles more than thirty years ago. Since asphalt shingles have a lifetime of less then 20 years, tear off shingles should not contain asbestos. However, because asphalt shingles can be applied over one course of old shingles, it is possible that shingles containing asbestos could be delivered to a recycling facility. More importantly, “asbestos may be present at low frequency and in small amounts in other related roofing materials such as roofing felt and mastic”.5

3 Ibid. 4 Ibid. See R2005A-TS-2c: Provisional Standard Recommended Practice for Design Considerations when using Reclaimed Asphalt Shingles in New Hot Mix Asphalt 5 Townsend, Dr. Timothy, Xu, Dr. Chad, Powell, Jon. (October 2007) Environmental Issues Associated with Asphalt Shingle Recycling.



MSW Team member DSM surveyed asphalt shingle recyclers in Massachusetts. They are required by state regulation to test for asbestos. This adds to the cost of recycling the asphalt shingles and requires that storage of delivered asphalt be segregated so that if asbestos is found during testing that the material containing the asbestos can be identified and landfilled. It was reported to DSM by one of the largest asphalt recyclers in Massachusetts that asbestos has only been found on “one or two” occasions, and in both cases in very low concentrations. While the cost to test is not great, the procedure for establishing a sampling protocol that is sufficient to address this issue could be difficult, and may be the largest single deterrent to recycling asphalt shingles.

5.7. CONCLUSION

The materials discussed in this section were targeted opportunistically based on the research approach that was developed to investigate wood pallets and clean wood. For this reason, the results shown here are not intended to portray a detailed, County-wide analysis of the generation, recycling and disposal of these materials.

However, the following observations can be made based on the research performed:

OCC appears to be widely recycled among the businesses targeted for investigation in this project, although over 9,000 tons of OCC was still found to be disposed from these businesses. It is perhaps noteworthy that the County’s prior commercial waste characterization study projected over 57,000 tons of OCC being disposed as MSW.

Over 3,600 tons of recyclable film plastics were found to be disposed within the universe of commercial businesses studied. The County’s prior commercial waste characterization study estimated 1,200 tons of transport packaging film (as well as xxx tons of all films). Another 1,300 tons of plastic films were disposed in C&D landfills.

Both OCC and film plastics are likely to be generated broadly among the Possible Generator and the Unlikely Generator strata, as defined in this study. These results should not be considered representative of OCC and film plastic generation, disposal and recycling across the remaining universe of County businesses. It was beyond the scope of this project to project total OCC and film plastic generation, but it is likely that both materials are generated ubiquitously with recycling of these materials becoming more challenging as the generator gets smaller.

Collection and disposal of C&D debris in Mecklenburg County continues to be governed by the relative low cost of mixed wastes being disposed in C&D landfills in the region. While there are highly recyclable materials contained in the C&D, the cost of source separating and separately collecting/transporting has reduced the incentive to recycle at the current time. As discussed in the pallet/wood results section, C&D recycling could be positively impacted by recycling/diversion regulations that apply uniformly to all builders, so as to place all stakeholders on a level playing field.

With the exception of asphalt shingles, the cleanliness of the potentially recyclable material will be among the factors that influences the recyclability of the material. Film plastic (especially), drywall, and vinyl recyclers all require a relatively clean feedstock, so excessive contamination of these materials may eliminate recycling opportunities (or else increase the handling cost sufficiently to eliminate any financial gain).



Asphalt shingle recycling could potentially be developed by the County, provided that the cost to store, grind, test for asbestos and transport to a hot mix asphalt producer are competitive with landfill costs after the sale of the ground asphalt.

Mecklenburg County Pallet/Woodwaste Report

APPENDIX A Pallet Nomenclature

(Source: National Wooden Pallet & Container Association)

1

Pallet Classification Pallet Classification defines Pallet Size, Class, Type, Style, Construction, and Use Category. Terminology is consistent with the NWPCA Uniform Standard for Wood Pallets.

Pallet ID is your own name or identification for this pallet design (maximum 60 characters). It will be displayed on all printouts and drawings for this pallet.

Pallet Size is the overall pallet dimensions expressed as Pallet Length × Pallet Width.

Pallet Length is the length of the Stringers (Stringer-class pallets) or Top Stringerboards (Block-class pallets). For Panel-deck Block-class pallets without stringerboards, Pallet Length is typically the pallet dimension parallel to the Top Panel Deck strong axis.

Pallet Length

Pallet Width is the length of the Top Deckboards. For Panel-deck pallets, Pallet Width is the Top Panel Deck dimension perpendicular to Pallet Length.

Pallet Width

Pallet Class defines the basic pallet design class:

• Stringer-class pallets utilize rectangular stringers (or runners) - wood components that run the full length of the pallet. The top deck is fastened to the top edge of the stringers. For Double-face pallets, the bottom deck is fastened to the bottom edge of the stringers.

• Block-class pallets utilize rectangular blocks (or cylindrical posts), which separate the top deck from bottom deck (if Double-Face). Block-class pallets with lumber decks have top stringerboards, which run the full length of the pallet and are fastened to the blocks.

2

The Pallet Use Category is defined in the NWPCA Uniform Standard for Wood Pallets:

• Multiple-Use Pallets are intended for repeated uses for more than one unit load. Multiple-Use Pallets are also referred to as Returnable Pallets.

• Limited-Use Pallets are intended for use with a single unit load. Limited-Use Pallets are also referred to as Shipping Pallets.

Pallet Style defines the basic construction style of the pallet:

• Single-Face pallets have only one deck and are also referred to as Skids.

Single-Face

• Double-Face Non-Reversible pallets have a specific top face and a specific bottom face, which are not interchangeable.

Double-Face Non-Reversible

• Double-Face Reversible pallets have a top and bottom deck which are identical, so the pallet can be used "reversibly".

Double-Face Reversible

3

Entry Type further defines the pallet design and indicates how the pallet may be entered by forklift and pallet jack equipment:

• 2-Way pallet designs are Stringer-Class pallets without stringer notches. They can be entered and lifted by forklift and pallet jack from only the two ends, thus the term 2-Way entry.

2-Way

• Partial 4-Way pallet designs include Stringer-Class pallets with stringers notched for fork tine entry. These notches are rarely sized to accommodate pallet jacks, which can only enter the pallet from the ends. Only forklifts can enter and lift the pallet from the sides as well as ends, thus the term Partial 4-Way entry.

Partial 4-Way

• Partial 4-Way pallet designs also include Block-Class pallets with an Overlap Base. The overlapped bottom stringerboards and bottom deckboards typically prevents the entry of pallet jack wheels over the bottom stringerboards (without damaging the pallet), but pallet jacks can enter the pallet over the bottom deckboards. Only forklifts can enter and lift the pallet from all 4 directions, thus the term Partial 4-Way entry.

Partial 4-Way

• Full 4-Way pallet designs are Single-Face Block-Class pallets or Double-Face Non-Reversible Block-Class pallets with a Panel Base, Perimeter Base, or Unidirectional Base. The single layer bottom deck (if present) and potentially large openings between blocks (or posts) allows entry of forklifts or pallet jacks from all pallet sides and ends, thus the term Full 4-Way entry.

Full 4-Way

4

PDS allows the following Top Deck Constructions for each Pallet Class:

Stringer-Class:

• Deckboard

• Panel

Block-Class:

• Deckboard/Stringerboard

• Panel

• Panel/Stringerboard

Deckboard Top Deck Constructions apply to Stringer-class pallets with lumber Top Deckboards.

DeckboardStringer

Deckboard/Stringerboard Top Deck Constructions apply to Block-class pallets with lumber Top Deckboards attached to Top Stringerboards.

DeckboardStringerboard

Block

Top Panel Deck Constructions apply to Stringer-class pallets and Block-class pallets without Top Stringerboards.

PanelBlock

PanelStringer

Panel/Stringerboard Top Deck Constructions apply to Block-class pallets with a Top Panel Deck attached to Top Stringerboards.

PanelStringerboard

Block

5

PDS allows the following Bottom Deck Constructions for each Pallet Class:

Stringer-Class:

• Deckboard

• Panel Base

Block-Class:

• Panel Base

• Perimeter Base

• Overlap Base

• Unidirectional Base

Deckboard Bottom Deck Constructions apply to Stringer-class pallets with lumber Bottom Deckboards.

DeckboardStringer

Panel Base Bottom Deck Constructions apply to Stringer-class pallets or Block-class pallets with a bottom deck panel.

PanelBlock

PanelStringer

Perimeter Base Bottom Deck Constructions may be used on Block-class pallets and are characterized by boards oriented in both directions but in the same plane. There are boards continuously around the bottom deck perimeter - hence the term Perimeter Base.

6

Overlap Base Bottom Deck Constructions may be used on Block-class pallets and are characterized by bottom deckboards and bottom stringerboards oriented in opposite directions. The deckboards and stringerboards are overlapped at the blocks - hence the term Overlap Base.

Unidirectional Base Bottom Deck Constructions may be used on Block-class pallets. They are characterized by having bottom deckboards that may be oriented along the pallet length or the pallet width. The deckboards run in only one direction - hence the term Unidirectional Base.

Deck Style further defines construction style of pallet decks.

• Flush: ends of deckboards and edges of panels are Flush with stringer or stringerboard edge. For Panel Deck Block-class pallets without stringerboards, panel edges are Flush with block edges.

• Single-Wing: ends of top deckboards and edges of top panels overhang stringer or stringerboard edge. Bottom Deck, if present, is Flush.

• Double-Wing: ends of top and bottom deckboards and edges of top and bottom panels overhang stringer or stringerboard edge. Bottom Wing must be ≤ Top Wing.

7

Stringerboard Style further defines construction style of Block-class pallets with stringerboards.

• Flush: ends of stringerboards are Flush with ends of blocks.

• Single-Cantilever: ends of top stringerboards overhang ends of blocks. Ends of bottom stringerboards, if present, are Flush with ends of blocks.

• Double-Cantilever: Overlap Base Block-class pallets only. Ends of top and bottom stringerboards overhang ends of blocks. Top and bottom stringerboards must be parallel, and Bottom Cantilever must be ≤ Top Cantilever.

Bottom Deck Orientation may be specified for Block-class pallets.

• Overlap Base or Unidirectional Base: Bottom Deckboards may be Parallel or Perpendicular to Pallet Length.

• Perimeter Base: Butted Boards may be Parallel or Perpendicular to Pallet Length. Outer Boards will be oriented opposite direction.

8

Length Width

Length Width

Length Width

Parallel to Pallet Length

Length Width

Length Width

Length Width

Perpendicular to Pallet Length


APPENDIX B

Commercial Generator Survey Instrument

6225 Sawyer Road, New Market, MD, 21774 (301) 607-6428 842 Spring Island Way, Orlando, FL 32828 (407) 380-8951 2291 Limehurst Drive, Atlanta, GA 30319 (404) 496-4872

Business Name: __________________________________ ID # : ___________________ Address: ________________________________________ NAICS Code: ___________________ _________________________________________ NAICS Business Type: ____________________ Square Footage: # of Employees: ________ # of Full Time Employees:

MECKLENBURG COUNTY Wood Pallet and Clean Wood Waste Recycling Study

Mecklenburg County has retained MidAtlantic Solid Waste Consultants to conduct a study of wood pallet and clean wood recycling within the County. As part of the study, we are contacting businesses in the county to gain insight on the issue. We are requesting your participation and feedback in this study. Please provide responses to Veronica Roof of MSW Consultants (email [email protected]; phone 888/MSW-9220; fax 301/591-4471). Thank you for your assistance on this important County project.

I. GENERAL INFORMATION

1. Please confirm the accuracy of the information above and make corrections as necessary. Enter the number of Full-time Equivalent (FTE) employees if different from the number of employees shown.

2. Where is your business located? In its own stand alone building (continue survey) In an Office Building with other businesses

In a strip mall/commercial building complex In a Home Office (survey complete)

3. Do you contract directly for garbage and recycling collection services or does a property manager contract for collection services on behalf of your business?

Business contracts for collection services Property manager contracts for collection

services on our behalf

II. TARGETED RECYCLABLE MATERIALS This survey is targeting the following recyclable materials: Wood Pallet: Flat structure made of wood which can support a variety of goods in a stable fashion while being lifted by any mobile forklift device. Clean Wood: Any uncontaminated natural or untreated wood such as wood scraps and dimensional lumber. Does not include wood that has been treated, painted, stained, coated, engineered with glues or resins, or chemically changed in some way. Film Plastics: Includes shrink wrap, stretch wrap, tarps, shopping bags and other plastic films made out of #2 HPDE or #4 LDPE. Corrugated Cardboard: Includes boxes and other packaging products made out of brown paper, with two heavy outer layers and a fluted inner layer to provide strength.

4. Please check which of the following materials your business generates as a waste material.

Wood Pallets Clean Wood Film Plastics Corrugated Cardboard None of the above

III. SPECIFIC GENERATION INFORMATION Please answer only the questions in this section that are applicable to the materials generated by your business as identified in Question 4 above.

5. If your business generates Wood Pallets… Please estimate how many wood pallets your business generates on average.

We generate approximately wood pallets (enter number of pallets) per week/month/year (circle one).

Does your business currently recycle wood pallets?

No Yes - my pallets are recycled by: A pallet recycling company Name of company: ___________________ Other Name of company: ___________________

of 2

6. If your business generates Clean Wood…

Please estimate how much clean wood your business generates on average.

We generate approximately ___ cubic yards of clean wood per week/month/year (circle one).

Does your business currently recycle clean wood?

No Yes - my clean wood is recycled by: A recycling company Name of company: ___________________

Other Name of company: ___________________

7. If your business generates Film Plastic… Please estimate how much film plastic your business generates on average.

Volume or weight (please specify a number): Bales (average dimension is L____ x W____ x H ____ inches) Bags or other containers (average size is ____ gallons) Uncompacted cubic yards Compacted cubic yards Pounds

Per unit of time

week month year

Or, describe how much film plastic you generate: ____________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________

Does your business recycle film plastic? No Yes – How does your business recycle film plastic? _______________________________________________

8. If your business generates Corrugated Cardboard…

Please estimate how much corrugated cardboard your business generates on average.

Volume or weight (please specify a number): Bales (average dimension is L____ x W____ x H ____ inches) Containers (average size is ____ cubic yards) Uncompacted cubic yards Compacted cubic yards Pounds

Per unit of time

week month year

Or, describe how much corrugated cardboard you generate:___________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________ Does your business have a baler or separate container outside from which recycled cardboard is collected? Baler Separate Container

IV. OTHER GENERAL INFORMATION

9. Would you be willing to assist the County further its research into the generation and recycling of pallets, clean wood, film plastic and corrugated cardboard?

Yes, I would participate in another phone call to discuss recycling of these items in more detail. Yes, a County recycling representative may visit our business for on-site research into the recycling of these materials. No, please do not contact me again.

10. Please provide your contact information (or that of the appropriate staff member) if you are willing to assist us further.

Name: Title:

Phone Number: Email Address:


APPENDIX C

QCTS Commercial Waste Observation Data

Appendix C Queen City Transfer Station Observation Raw Data

Line #

Sheet #

Time of Delivery Date Truck #

Net Weight (tons)

Truck Type

Roll-off

Type

Size of Truck (CY)

Pct Full

MSW or C&D Load

Pallets: % of Load

# of Pallets (reusable & not usable)

# of Crates

Clean Wood: % of Load Describe Clean Wood Waste

1 1 6:53 8/7/2007 WM 207523 9.96 FL 40 75% MSW 0% 0 0% Commercial Route2 1 6:58 8/7/2007 REP340 3.97 RO SC 20 50% MSW 0% 0 0% Restaurant3 1 6:59 8/7/2007 WM409062 1.94 RO OT 30 75% MSW 50% 2 8 40% Farm Industrial Location Packing Cra4 1 7:01 8/7/2007 AP12 8.64 RO C 40 100% MSW 0% 0 0% Retail Store5 1 7:08 8/7/2007 WM933 6.01 RO SC 30 90% MSW <1 1 <1 Retail?6 1 7:13 8/7/2007 AP70 8.84 FL 35 50% MSW <1 1 0% Commercial Route7 1 7:20 8/7/2007 REP364 6.20 RO OT 30 95% C&D 0% 0 0% Construction Demo8 1 7:25 8/7/2007 REP312 3.20 RO OT 30 90% C&D 0% 0 80% Particle board from cabinet maker9 1 7:39 8/7/2007 WM717 4.60 RO SC 30 95% MSW 0% 0 0% Industrial (MFG)

10 1 7:49 8/7/2007 REP244 9.58 FL 40 100% MSW <1 3 10% Lumber (cut-off 2 x4 and 2x611 1 8:06 8/7/2007 AP120 15.47 RO SC 30 75% MSW 0% 0 0% Hotel and Restaurant12 1 8:10 8/7/2007 REP364 3.76 RO OT 20 95% C&D 0% 0 0% Demolition (drywall / carpet)13 1 8:20 8/7/2007 AP19 3.36 RO C 40 80% MSW 5% 8 1% 2 x 414 1 8:29 8/7/2007 NS40717 1.03 RO C 40 20% MSW 0% 0 0% Retail15 1 8:45 8/7/2007 WM5625 8.63 FL 40 65% MSW 0% 0 0% Commercial Route (fair amount of O1 2 8:46 8/7/2007 REP 265 10.04 FL 40 50% MSW <1 1 0% 5% OCC Commercial Route2 2 8:55 8/7/2007 REP 359 2.62 RO OT 40 58% MSW 70% 8 0% Industrial3 2 9:07 8/7/2007 SHA 403 1.16 RO OT 30 95% MSW 0% 0 0% OCC 8%4 2 9:15 8/7/2007 REP 314 2.37 RO OT 40 65% MSW 1% 4 0% Industrial5 2 9:25 8/7/2007 AC 401 0.25 RO OT 10 95% C&D 0% 0 95% Clean wood construction6 2 9:35 8/7/2007 WM 411872 2.23 RO OT 30 105% MSW 5% 8 5% Woodworking shop janitorial7 2 9:45 8/7/2007 WM 543 9.58 FL 40 60% MSW 0% 0 0% OCC 25%8 2 9:52 8/7/2007 REP 340 2.69 RO OT 30 95% MSW 10% 10 0% Industrial9 2 9:59 8/7/2007 REP 301 3.09 RO OT 30 95% C&D 1% 2 75% Lumber from construction

10 2 10:15 8/7/2007 REP 359 10.65 RO SC 30 95% MSW <1 1 0% Grocery 5% OCC11 2 10:20 8/7/2007 REP 313 2.80 RO OT 40 100% MSW 5% 6 2% Lumber12 2 10:25 8/7/2007 WM 933 5.95 RO C 40 100% MSW <1 2 1% Lumber / Plywood13 2 10:30 8/7/2007 REP 361 2.05 RO OT 40 100% MSW 80% 25 2 15%14 2 10:38 8/7/2007 REP 221 10.89 FL 40 35% MSW 0% 0 0% Commercial Route15 2 10:42 8/7/2007 REP 227 5.12 FL 40 70% MSW <1 3 0% Commercial Route1 3 10:43 8/7/2007 AP 45 9.87 RO SC 40 80% MSW 1% 4 0% Commercial ?2 3 10:56 8/7/2007 REP 266 3.68 FL 40 80% MSW <1 1 0% Commercial Route3 3 12:07 8/7/2007 AP 70 9.42 FL 40 75% MSW 0% 0 1% Lumber Commercial Route 5% OCC4 3 12:10 8/7/2007 REP 312 3.04 RO C 40 90% MSW 0% 0 0% 40% OCC 5 3 12:13 8/7/2007 REP 323 1.62 RO OT 30 85% MSW 5% 11 0% Industrial ?6 3 12:16 8/7/2007 WM 519 1.76 RO OT 30 80% MSW 4% 8 0% 15% OCC7 3 12:22 8/7/2007 WM 708 0.30 RO OT 30 90% MSW 2% 2 1 0% Industrial?

Page 1 of 5


Line #

Sheet #


Net Weight (tons)

Truck Type

Roll-off

Type

Size of Truck (CY)

Pct Full

MSW or C&D Load

Pallets: % of Load


# of Crates


8 3 12:28 8/7/2007 REP 2489 6.28 FL OT 40 50% MSW 1% 3 2% Commercial Route Lumber9 3 12:36 8/7/2007 WM 726 2.41 RO OT 30 90% MSW 0% 0 0% Residential Cleanout

10 3 12:43 8/7/2007 REP 265 5.85 FL OT 40 50% MSW 2% 3 2% Commercial Route Lumber12 3 12:45 8/7/2007 REP 244 4.38 FL OT 40 50% MSW 2% 5 4% New lumber scraps11 3 12:45 8/7/2007 WM 725 2.02 RO OT 30 90% MSW <1 1 6% 30% OCC13 3 12:46 8/7/2007 REP 361 3.29 RO OT 30 70% MSW <1 8 2% Lumber14 3 12:50 8/7/2007 REP 364 25.09 RO OT 30 80% C&D <1 1 0% Asphalt1 4 13:24 8/7/2007 WM 708 0.30 RO OT 30 95% MSW 15% 5 1 0% 10% OCC2 4 13:45 8/7/2007 REP 264 8.14 FL 40 65% MSW 0% 0 2% Lumber3 4 13:46 8/7/2007 REP 340 6.67 RO C 40 100% MSW 0% 0 0% 35% OCC4 4 13:49 8/7/2007 CWS 12 7.50 RO OT 10 95% C&D 0% 0 0% 25% Fake rock5 4 13:50 8/7/2007 AP 120 2.10 RO SC 30 90% MSW 0% 0 0% Grocery6 4 13:55 8/7/2007 WM 519 3.50 RO OT 40 90% MSW 0% 0 0% 10% Metal7 4 13:58 8/7/2007 REP 301 0.74 RO OT 30 95% MSW 5% 5 0% 10% OCC8 4 14:00 8/7/2007 REP 273 1.29 FL 40 75% MSW 1% 3 0% Commercial Route 5% OCC9 4 14:05 8/7/2007 WM 543 11.31 FL 40 85% MSW 1% 2 0% Loaded with glass (beer bottles)

10 4 14:08 8/7/2007 REP 359 37.00 RO OT 30 80% MSW 2% 2 0% 35% OCC 11 4 14:13 8/7/2007 REP 312 1.34 RO OT 30 85% MSW 4% 2 2 0% 40% OCC Industrial12 4 14:23 8/7/2007 WM 872 3.96 RO OT 30 90% MSW 3% 1 1 0% 20% OCC13 4 14:30 8/7/2007 AP 113 2.81 RO C 40 80% MSW 2% 2 0% 40% 30% OCC14 4 14:31 8/7/2007 REP 340 3.60 RO C 40 95% MSW 1% 3 0% 70% OCC2 1 6:53 8/8/2007 WM 543 7.41 FL 40 80% MSW 2% 4 0% 10% OCC Commercial Route1 1 6:55 8/8/2007 WM 900 2.48 FL 35 20% MSW 0% 0 0% 40% OCC Commercial Route3 1 7:05 8/8/2007 WM 825 11.59 FL 40 80% MSW 0% 0 0% Commercial Rout4 1 7:10 8/8/2007 REP 340 1.03 RO SC 30 25% MSW 0% 0 0% Restaurant5 1 7:11 8/8/2007 AP 120 5.52 RO SC 30 40% MSW <1 1 0% Hotel 6 1 7:15 8/8/2007 REP 323 54.00 RO OT 40 80% MSW 100% 25 0% Industrial 7 1 7:17 8/8/2007 WM 258 3.04 RO OT 20 65% C&D 10% 3 2% Lumber 8 1 7:21 8/8/2007 WM 933 2.29 RO OT 30 90% MSW 1% 2 0% 20% OCC9 1 7:22 8/8/2007 WM 726 3.47 RO SC 30 80% MSW 0% 0 0% Hospital

10 1 7:30 8/8/2007 REP 312 7.94 RO C 40 75% MSW <1 1 0% Industrial11 1 7:32 8/8/2007 AP 17 4.16 RO SC 40 95% MSW 0% 0 0% Grocery 5% OCC12 1 7:41 8/8/2007 REP 359 1.63 RO OT 40 90% MSW 80% 25 0% Industrial13 1 7:42 8/8/2007 REP 361 2.56 RO OT 30 95% MSW 100% 42 0% Industrial14 1 7:43 8/8/2007 REP 364 1.16 OR OT 30 90% C&D 0% 0 0% C&D Carpet 5%1 2 7:45 8/8/2007 CWS 190 5.88 RO OT 30 95% C&D <1 1 0%

15 1 7:46 8/8/2007 REP 301 2.18 RO OT 20 95% C&D 0% 0 0% 80% Painted Wood

Page 2 of 5


Line #

Sheet #


Net Weight (tons)

Truck Type

Roll-off

Type

Size of Truck (CY)

Pct Full

MSW or C&D Load

Pallets: % of Load


# of Crates


2 2 7:50 8/8/2007 REP 234 8.24 FL 40 10% MSW 1% 3 0% Commercial Route3 2 7:58 8/8/2007 WM 720 12.13 RO OT 30 95% MSW 25% 11 0% 25% OCC4 2 8:01 8/8/2007 REP 240 8.42 FL 40 100% MSW 1% 2 2%5 2 8:05 8/8/2007 AP 29 12.13 FL 40 100% MSW <1 1 0% Commercial Route6 2 8:08 8/8/2007 REP 244 9.00 FL 40 100% MSW 100% 3 0% Commercial Route 5% OCC7 2 8:09 8/8/2007 REP 323 12.25 RO SC 30 100% MSW 0% 0 0% Industrial 10% OCC8 2 8:11 8/8/2007 REP 340 9.05 RO OT 30 95% C&D 0% 0 0% Demolition (painted wood)9 2 8:12 8/8/2007 REP 264 11.88 FL 40 100% MSW 0% 0 0% 5% OCC

10 2 8:15 8/8/2007 WP 933 0.76 RO OT 30 95% MSW 90% 26 0% 5% OCC Industrial11 2 8:22 8/8/2007 REP 364 0.94 RO OT 30 95% MSW 5% 6 35%12 2 8:25 8/8/2007 WM 725 8.08 RO C 40 95% MSW 0% 0 0% 10% OCC Industrial or Retail13 2 8:26 8/8/2007 AP 54 11.24 FL 40 80% MSW 0% 0 0%14 2 8:28 8/8/2007 REP 265 8.07 FL 40 100% MSW <1 1 0% Commercial Route15 2 8:30 8/8/2007 WM 544 7.61 FL 40 95% MSW <1 1 0% Commercial Route1 3 8:40 8/8/2007 REP 303 4.79 RO OT 40 85% C&D 0% 0 0% Demolition (painted wood)2 3 8:42 8/8/2007 REP 361 0.67 RO OT 30 90% MSW <1 1 0% Retail 40% OCC3 3 8:45 8/8/2007 AP 41 6.50 FL 40 100% MSW <1 1 0% Commercial Route 5 to 10% OCC4 3 8:50 8/8/2007 CWS 2 4.70 RO OT 30 95% MSW 15% 6 25% Building shop clean lumber & plywoo5 3 8:55 8/8/2007 WM 872 1.12 RO SC 30 60% MSW 0% 0 0% 40% OCC Industrial6 3 8:58 8/8/2007 WM 933 0.82 RO OT 30 85% MSW 0% 0 0% 20% OCC Industrial7 3 8:58 8/8/2007 REP 2489 9.44 FL 40 95% MSW <1 2 0% Commercial Route8 3 9:00 8/8/2007 AP 120 8.50 RO SC 30 85% MSW 0% 0 0% Grocery9 3 9:06 8/8/2007 REP 364 0.83 RO OT 30 95% C&D 0% 0 5% Lumber scrap 10% OCC

10 3 9:08 8/8/2007 REP 312 1.40 RO OT 30 95% MSW 5% 5 2% Lumber scraps11 3 9:12 8/8/2007 359 2.00 RO OT 40 90% MSW 1% 1 0% 10% OCC12 3 9:15 8/8/2007 WM061 1.19 RO OT 30 95% MSW <1 1 0% 20% OCC13 3 9:16 8/8/2007 WM 062 2.38 RO OT 40 95% MSW 75% 14 5 0%14 3 9:18 8/8/2007 WM 519 2.06 RO OT 20 90% MSW 0% 0 0%15 3 9:20 8/8/2007 REP 340 1.41 RO OT 30 95% MSW 45% 14 15%1 4 9:40 8/8/2007 REP 364 0.40 RO OT 30 80% MSW 10% 5 0% 20% OCC2 4 9:50 8/8/2007 REP 307 2.99 RO OT 40 90% MSW 3% 4 0%3 4 9:55 8/8/2007 REP271 5.08 FL 40 85% MSW 0% 0 0% 54 4 9:57 8/8/2007 AP 17 11.57 RO SC 30 95% MSW 0% 0 0% Grocery5 4 10:00 8/8/2007 WM 933 2.97 RO C 40 90% MSW 20% 6 20% 25% OCC6 4 10:02 8/8/2007 REP 312 5.63 RO SC 30 95% MSW 0% 0 0% 10% OCC7 4 10:05 8/8/2007 REP 303 4.85 RO C 40 75% MSW 0% 0 0% Retail 25% OCC 25% 8 4 10:06 8/8/2007 REP 340 5.65 RO OT 30 95% C&D 0% 0 0% 20% Dirt

Page 3 of 5


Line #

Sheet #


Net Weight (tons)

Truck Type

Roll-off

Type

Size of Truck (CY)

Pct Full

MSW or C&D Load

Pallets: % of Load


# of Crates


9 4 10:12 8/8/2007 REP 234 3.19 FL 40 90% MSW 0% 0 0% 10% OCC10 4 10:16 8/8/2007 REP 327 1.78 RO OT 40 90% MSW 65% 18 5% 5% OCC Broken wood from pallets11 4 10:20 8/8/2007 REP 359 6.18 RO OT 30 95% MSW 0% 0 5% Demolition (sheet rock 30%) Plywoo12 4 10:20 8/8/2007 REP 266 11.63 FL 40 100% MSW <1 1 0% Commercial Route13 4 10:27 8/8/2007 WM 872 1.26 RO OT 30 95% MSW 20% 8 5% Clean wood from broken pallets14 4 10:30 8/8/2007 WM 625 11.71 FL 40 80% MSW 0% 0 0% Commercial Route15 4 10:35 8/8/2007 REP 244 6.85 FL 40 45% MSW 0% 3 5% Commercial Route (cabinet maker)1 5 10:40 8/8/2007 WM 062 2.25 FL 40 80% MSW <1 1 0%3 5 10:45 8/8/2007 CWS 2 2.49 RO OT 30 85% C&D 1% 2 0% Demolition2 5 10:45 8/8/2007 AP 29 9.06 RO OT 40 95% MSW 75% 8 5 0% Industrial4 5 10:48 8/8/2007 AP 120 4.76 RO SC 30 90% MSW <1 2 0% Retail 5% OCC5 5 10:50 8/8/2007 WM 933 2.65 RO C 40 85% MSW 10% 9 0% 30% OCC6 5 12:50 8/8/2007 CWS 2 1.86 RO OT 30 85% MSW 20% 6 0% 10% OCC7 5 12:50 8/8/2007 WM 519 3.36 RO OT 40 90% MSW 90% 32 1 5% Plywood/OSB9 5 12:55 8/8/2007 WM 872 3.01 RO OT 40 90% C&D 10% 9 20% Lumber

10 5 12:55 8/8/2007 REP 364 4.00 RO OT 30 95% C&D 0% 0 0% 5% OCC8 5 12:55 8/8/2007 REP 301 0.96 RO OT 40 95% MSW 1% 2 0% 75% OCC

11 5 13:05 8/8/2007 WM 062 3.17 RO OT 30 80% MSW 100% 42 0%12 5 13:05 8/8/2007 REP 340 2.11 RO OT 30 95% MSW 20% 10 85% + lumber13 5 13:10 8/8/2007 REP 312 5.58 RO OT 30 95% C&D 0% 0 0% Painted wood Demolition 5% stained14 5 13:12 8/8/2007 REP 212 2.37 FL 40 60% MSW 3% 5 0% 5% OCC Commercial Route15 5 13:15 8/8/2007 WM 726 3.46 RO C 40 100% MSW 0% 0 0% 5% OCC 3% Office paper1 6 13:25 8/8/2007 WM 933 4.89 RO SC 30 80% MSW 0% 0 0% Grocery2 6 13:27 8/8/2007 REP 314 2.37 RO OT 30 95% C&D 0% 0 0% Demolition 25% Painted wood 5% O5 6 13:30 8/8/2007 WM 961 2.61 FL 40 75% MSW 0% 0 0%3 6 13:30 8/8/2007 AP 17 2.04 RO C 40 90% MSW <1 2 0% Industrial 4 6 13:34 8/8/2007 AWG 9463 1.33 RO OT 10 100% C&D 0% 0 0% 50% OCC 5% metal6 6 13:40 8/8/2007 REP 307 1.88 RO OT 30 110% C&D 0% 0 0% Old furniture 50%7 6 13:43 8/8/2007 WM 061 2.61 RO SC 20 45% MSW 0% 0 0% Office 5% OCC8 6 13:48 8/8/2007 CWS 5 1.27 RO OT 30 85% MSW 25% 7 0%9 6 13:55 8/8/2007 REP 364 8.17 RO OT 30 45% C&D 0% 0 0% 25% Yard waste 20% concrete & dir

10 6 13:57 8/8/2007 REP 301 4.53 RO OT 40 90% C&D 2% 2 0% 90% sheet rock12 6 14:00 8/8/2007 REP 291 3.24 FL 40 45% MSW 0% 0 0%11 6 14:00 8/8/2007 REP 361 1.82 RO OT 30 95% C&D 10% 6 5% 5% OCC lumber cutoffs13 6 14:05 8/8/2007 WM 872 1.37 RO OT 40 85% MSW 0% 0 0% Grocery14 6 14:08 8/8/2007 AP 112 16.55 RO SC 30 85% MSW 1% 3 0%

Page 4 of 5


Line #

Sheet #


Net Weight (tons)

Truck Type

Roll-off

Type

Size of Truck (CY)

Pct Full

MSW or C&D Load

Pallets: % of Load


# of Crates


Total incoming Trucks on 8/7/07 240Total incoming Trucks on 8/8/07 to 3:00 P.M. 171

Total Trucks 411Total Trucks Observed 147

Percent Trucks Observ 36%

AbbreviationsRO = Roll-offFL = FrontloaderOT = Open Top Roll-offSC= Self Contained Compactor Roll-offC= Compactor Roll-off

Page 5 of 5


APPENDIX D

NAICS Code Assignment Exhibits

Exhibit 1: 5-Digit NAICS Codes Identified as Likely Generators of Wood Pallets and/or Clean WoodNAICS 5-Digit Code Title

Count of Businesses

Total Employees


11142 Nursery and Floriculture Production 5 41 16,250 31121 Flour Milling and Malt Manufacturing 2 40 50,000 31122 Starch and Vegetable Fats and Oils Manufacturing 1 120 50,000 31131 Sugar Manufacturing 1 2 6,250 31151 Dairy Product (except Frozen) Manufacturing 1 4 25,000 31152 Ice Cream and Frozen Dessert Manufacturing 4 48 100,000 31161 Animal Slaughtering and Processing 5 249 150,000 31171 Seafood Product Preparation and Packaging 1 15 25,000 31181 Bread and Bakery Product Manufacturing 18 532 141,250 31182 Cookie, Cracker, and Pasta Manufacturing 1 8 25,000 31191 Snack Food Manufacturing 4 1,861 150,000 31192 Coffee and Tea Manufacturing 2 41 31,250 31199 All Other Food Manufacturing 11 342 300,000 31211 Soft Drink and Ice Manufacturing 9 1,810 450,000 31212 Breweries 1 4 25,000 31222 Tobacco Product Manufacturing 1 4 25,000 31311 Fiber, Yarn, and Thread Mills 5 364 175,000 31321 Broadwoven Fabric Mills 3 104 81,250 31322 Narrow Fabric Mills and Schiffli Machine Embroidery 3 64 56,250 31323 Nonwoven Fabric Mills 3 82 100,000 31324 Knit Fabric Mills 2 19 50,000 31331 Textile and Fabric Finishing Mills 15 105 300,000 31332 Fabric Coating Mills 1 5 25,000 31411 Carpet and Rug Mills 1 5 25,000 31412 Curtain and Linen Mills 1 200 50,000 31491 Textile Bag and Canvas Mills 4 184 125,000 31499 All Other Textile Product Mills 28 504 587,500 31511 Hosiery and Sock Mills 1 600 50,000 31522 Men's and Boys' Cut and Sew Apparel Manufacturing 1 8 25,000 31599 Apparel Accessories and Other Apparel Manufacturing 2 5 31,250 31699 Other Leather and Allied Product Manufacturing 3 5 18,750 32111 Sawmills and Wood Preservation 2 13 31,250 32121 Veneer, Plywood, and Engineered Wood Product Manufacturing 2 105 75,000

Page 1 of 7


Count of Businesses

Total Employees


32191 Millwork 22 783 787,500 32192 Wood Container and Pallet Manufacturing 1 90 50,000 32199 All Other Wood Product Manufacturing 8 98 168,750 32212 Paper Mills 9 141 212,500 32213 Paperboard Mills 6 300 200,000 32221 Paperboard Container Manufacturing 14 699 475,000 32222 Paper Bag and Coated and Treated Paper Manufacturing 13 265 300,000 32223 Stationery Product Manufacturing 5 210 137,500 32229 Other Converted Paper Product Manufacturing 3 95 100,000 32311 Printing 251 3,964 3,693,750 32312 Support Activities for Printing 13 208 350,000 32411 Petroleum Refineries 3 78 100,000 32412 Asphalt Paving, Roofing, and Saturated Materials Manufacturing 3 110 81,250 32512 Industrial Gas Manufacturing 1 10 25,000 32513 Synthetic Dye and Pigment Manufacturing 1 3 25,000 32518 Other Basic Inorganic Chemical Manufacturing 2 15 50,000 32519 Other Basic Organic Chemical Manufacturing 1 40 6,250 32521 Resin and Synthetic Rubber Manufacturing 19 834 512,500 32522 Artificial and Synthetic Fibers and Filaments Manufacturing 1 4 6,250 32531 Fertilizer Manufacturing 1 4 25,000 32532 Pesticide and Other Agricultural Chemical Manufacturing 1 1 6,250 32541 Pharmaceutical and Medicine Manufacturing 4 147 106,250 32551 Paint and Coating Manufacturing 3 38 100,000 32552 Adhesive Manufacturing 3 124 100,000 32561 Soap and Cleaning Compound Manufacturing 4 36 100,000 32562 Toilet Preparation Manufacturing 3 23 56,250 32591 Printing Ink Manufacturing 6 248 225,000 32599 All Other Chemical Product and Preparation Manufacturing 28 1,255 793,750 32611 Plastics Packaging Materials and Unlaminated Film and Sheet Manufacturing 5 60 125,000 32612 Plastics Pipe, Pipe Fitting, and Unlaminated Profile Shape Manufacturing 1 3 25,000 32613 Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing 3 45 75,000 32615 Urethane and Other Foam Product (except Polystyrene) Manufacturing 3 330 150,000 32619 Other Plastics Product Manufacturing 30 902 918,750

Page 2 of 7


Count of Businesses

Total Employees


32621 Tire Manufacturing 5 2,191 151,250 32622 Rubber and Plastics Hoses and Belting Manufacturing 3 208 81,250 32629 Other Rubber Product Manufacturing 6 85 131,250 32711 Pottery, Ceramics, and Plumbing Fixture Manufacturing 3 14 75,000 32712 Clay Building Material and Refractories Manufacturing 6 40 112,500 32721 Glass and Glass Product Manufacturing 8 58 143,750 32731 Cement Manufacturing 2 6 31,250 32732 Ready-Mix Concrete Manufacturing 4 104 125,000 32733 Concrete Pipe, Brick, and Block Manufacturing 2 111 75,000 32739 Other Concrete Product Manufacturing 7 516 262,500 32742 Gypsum Product Manufacturing 4 335 106,250 32791 Abrasive Product Manufacturing 3 42 75,000 32799 All Other Nonmetallic Mineral Product Manufacturing 5 62 106,250 33111 Iron and Steel Mills and Ferroalloy Manufacturing 4 112 112,500 33221 Cutlery and Handtool Manufacturing 10 64 231,250 33231 Plate Work and Fabricated Structural Product Manufacturing 26 1,156 806,250 33232 Ornamental and Architectural Metal Products Manufacturing 22 746 581,250 33251 Hardware Manufacturing 4 19 62,500 33261 Spring and Wire Product Manufacturing 9 335 181,250 33271 Machine Shops 47 487 1,043,750 33272 Turned Product and Screw, Nut, and Bolt Manufacturing 5 125 150,000 33291 Metal Valve Manufacturing 5 187 156,250 33299 All Other Fabricated Metal Product Manufacturing 22 1,265 581,250 33311 Agricultural Implement Manufacturing 5 302 175,000 33321 Sawmill and Woodworking Machinery Manufacturing 6 91 56,250 33411 Computer and Peripheral Equipment Manufacturing 7 213 200,000 33421 Telephone Apparatus Manufacturing 2 6 31,250 33422 Radio and Television Broadcasting and Wireless Communications Equipment Manufacturing 3 9 56,250 33429 Other Communications Equipment Manufacturing 5 76 125,000 33431 Audio and Video Equipment Manufacturing 2 30 50,000 33441 Semiconductor and Other Electronic Component Manufacturing 13 229 312,500 33451 Navigational, Measuring, Electromedical, and Control Instruments Manufacturing 29 436 656,250 33461 Manufacturing and Reproducing Magnetic and Optical Media 2 137 75,000

Page 3 of 7


Count of Businesses

Total Employees


33511 Electric Lamp Bulb and Part Manufacturing 1 5 25,000 33512 Lighting Fixture Manufacturing 1 11 25,000 33521 Small Electrical Appliance Manufacturing 3 11 56,250 33531 Electrical Equipment Manufacturing 12 239 287,500 33591 Battery Manufacturing 1 5 25,000 33592 Communication and Energy Wire and Cable Manufacturing 4 44 81,250 33599 All Other Electrical Equipment and Component Manufacturing 18 324 500,000 33632 Motor Vehicle Electrical and Electronic Equipment Manufacturing 1 35 25,000 33636 Motor Vehicle Seating and Interior Trim Manufacturing 2 50 50,000 33639 Other Motor Vehicle Parts Manufacturing 18 471 443,750 33641 Aerospace Product and Parts Manufacturing 3 149 81,250 33711 Wood Kitchen Cabinet and Countertop Manufacturing 77 540 1,718,750 33712 Household and Institutional Furniture Manufacturing 15 74 287,500 33721 Office Furniture (including Fixtures) Manufacturing 6 133 150,000 33791 Mattress Manufacturing 2 5 100,000 33792 Blind and Shade Manufacturing 1 118 50,000 33911 Medical Equipment and Supplies Manufacturing 51 1,996 1,256,250 33991 Jewelry and Silverware Manufacturing 7 16 81,250 33992 Sporting and Athletic Goods Manufacturing 8 36 50,000 33993 Doll, Toy, and Game Manufacturing 2 2 12,500 33994 Office Supplies (except Paper) Manufacturing 4 23 62,500 33995 Sign Manufacturing 74 400 462,500 33999 All Other Miscellaneous Manufacturing 61 1,852 1,743,750 42312 Motor Vehicle Supplies and New Parts Merchant Wholesalers 69 851 1,506,250 42313 Tire and Tube Merchant Wholesalers 8 106 206,250 42314 Motor Vehicle Parts (Used) Merchant Wholesalers 7 119 43,750 42321 Furniture Merchant Wholesalers 43 627 1,018,750 42331 Lumber, Plywood, Millwork, and Wood Panel Merchant Wholesalers 44 832 1,193,750 42332 Brick, Stone, and Related Construction Material Merchant Wholesalers 50 422 312,500 42333 Roofing, Siding, and Insulation Material Merchant Wholesalers 12 207 306,250 42339 Other Construction Material Merchant Wholesalers 15 331 171,250 42341 Photographic Equipment and Supplies Merchant Wholesalers 4 28 62,500 42342 Office Equipment Merchant Wholesalers 52 1,054 412,500

Page 4 of 7


Count of Businesses

Total Employees


42343 Computer and Computer Peripheral Equipment and Software Merchant Wholesalers 16 213 293,750 42344 Other Commercial Equipment Merchant Wholesalers 26 266 575,000 42345 Medical, Dental, and Hospital Equipment and Supplies Merchant Wholesalers 93 724 625,000 42346 Ophthalmic Goods Merchant Wholesalers 3 19 75,000 42349 Other Professional Equipment and Supplies Merchant Wholesalers 10 133 106,250 42351 Metal Service Centers and Other Metal Merchant Wholesalers 48 826 1,356,250 42352 Coal and Other Mineral and Ore Merchant Wholesalers 2 5 31,250 42361 Electrical Apparatus and Equipment, Wiring Supplies, and Related Equipment Merchant Wholesalers 244 3,643 6,093,750 42362 Electrical and Electronic Appliance, Television, and Radio Set Merchant Wholesalers 5 16 31,250 42369 Other Electronic Parts and Equipment Merchant Wholesalers 21 271 175,000 42371 Hardware Merchant Wholesalers 56 620 1,281,250 42372 Plumbing and Heating Equipment and Supplies (Hydronics) Merchant Wholesalers 32 229 518,750 42373 Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers 22 314 543,750 42382 Farm and Garden Machinery and Equipment Merchant Wholesalers 36 684 781,250 42383 Industrial Machinery and Equipment Merchant Wholesalers 215 2,677 4,731,250 42384 Industrial Supplies Merchant Wholesalers 74 1,096 1,806,250 42385 Service Establishment Equipment and Supplies Merchant Wholesalers 98 837 2,150,000 42386 Transportation Equipment and Supplies (except Motor Vehicle) Merchant Wholesalers 14 144 293,750 42391 Sporting and Recreational Goods and Supplies Merchant Wholesalers 28 136 175,000 42392 Toy and Hobby Goods and Supplies Merchant Wholesalers 23 171 468,750 42393 Recyclable Material Merchant Wholesalers 45 653 1,075,000 42394 Jewelry, Watch, Precious Stone, and Precious Metal Merchant Wholesalers 21 74 318,750 42399 Other Miscellaneous Durable Goods Merchant Wholesalers 235 3,098 4,868,750 42411 Printing and Writing Paper Merchant Wholesalers 18 320 556,250 42412 Stationery and Office Supplies Merchant Wholesalers 33 254 668,750 42413 Industrial and Personal Service Paper Merchant Wholesalers 37 291 831,250 42421 Drugs and Druggists' Sundries Merchant Wholesalers 15 91 337,500 42431 Piece Goods, Notions, and Other Dry Goods Merchant Wholesalers 1 15 25,000 42432 Men's and Boys' Clothing and Furnishings Merchant Wholesalers 16 44 193,750 42433 Women's, Children's, and Infants' Clothing and Accessories Merchant Wholesalers 12 642 268,750 42434 Footwear Merchant Wholesalers 5 33 87,500 42441 General Line Grocery Merchant Wholesalers 5 107 112,500 42442 Packaged Frozen Food Merchant Wholesalers 31 1,378 793,750

Page 5 of 7


Count of Businesses

Total Employees


42443 Dairy Product (except Dried or Canned) Merchant Wholesalers 7 95 87,500 42445 Confectionery Merchant Wholesalers 2 35 50,000 42446 Fish and Seafood Merchant Wholesalers 5 173 106,250 42447 Meat and Meat Product Merchant Wholesalers 5 28 87,500 42448 Fresh Fruit and Vegetable Merchant Wholesalers 6 125 175,000 42449 Other Grocery and Related Products Merchant Wholesalers 27 1,819 743,750 42461 Plastics Materials and Basic Forms and Shapes Merchant Wholesalers 10 184 262,500 42469 Other Chemical and Allied Products Merchant Wholesalers 67 471 1,337,500 42472 Petroleum and Petroleum Products Merchant Wholesalers (except Bulk Stations and Terminals) 32 361 200,000 42481 Beer and Ale Merchant Wholesalers 4 315 200,000 42482 Wine and Distilled Alcoholic Beverage Merchant Wholesalers 7 418 275,000 42491 Farm Supplies Merchant Wholesalers 14 45 200,000 42493 Flower, Nursery Stock, and Florists' Supplies Merchant Wholesalers 10 730 150,000 42495 Paint, Varnish, and Supplies Merchant Wholesalers 9 36 56,250 42499 Other Miscellaneous Nondurable Goods Merchant Wholesalers 34 333 343,750 44211 Furniture Stores 190 2,174 4,218,750 44221 Floor Covering Stores 107 804 768,750 44229 Other Home Furnishings Stores 113 746 706,250 44311 Appliance, Television, and Other Electronics Stores 194 2,323 1,387,500 44312 Computer and Software Stores 221 4,910 1,906,250 44411 Home Centers 61 3,021 1,968,750 44412 Paint and Wallpaper Stores 40 213 250,000 44413 Hardware Stores 27 243 187,500 44419 Other Building Material Dealers 270 3,027 4,987,500 44421 Outdoor Power Equipment Stores 9 154 51,250 44422 Nursery, Garden Center, and Farm Supply Stores 23 271 123,750 44511 Supermarkets and Other Grocery (except Convenience) Stores 129 9,202 1,870,000 48111 Scheduled Air Transportation 31 2,274 881,250 48121 Nonscheduled Air Transportation 9 35 112,500 48211 Rail Transportation 14 563 381,250 48321 Inland Water Transportation 7 14 100,000 48411 General Freight Trucking, Local 168 1,899 3,925,000 48421 Used Household and Office Goods Moving 1 1 6,250

Page 6 of 7


Count of Businesses

Total Employees


48423 Specialized Freight (except Used Goods) Trucking, Long-Distance 211 8,835 5,112,500 48811 Airport Operations 9 325 275,000 48819 Other Support Activities for Air Transportation 9 304 262,500 48821 Support Activities for Rail Transportation 37 244 775,000 48839 Other Support Activities for Water Transportation 1 1 6,250 49311 General Warehousing and Storage 26 506 1,300,000 49312 Refrigerated Warehousing and Storage 1 15 25,000 49313 Farm Product Warehousing and Storage 16 187 368,750 49319 Other Warehousing and Storage 4 81 68,750 56191 Packaging and Labeling Services 40 5,116 293,750 56192 Convention and Trade Show Organizers 15 218 137,500 62211 General Medical and Surgical Hospitals 29 4,168 1,287,500 62311 Nursing Care Facilities 42 3,906 1,350,000 62331 Community Care Facilities for the Elderly 48 3,574 1,043,750 62399 Other Residential Care Facilities 19 201 118,750 62411 Child and Youth Services 117 1,535 2,537,500 62412 Services for the Elderly and Persons with Disabilities 27 294 562,500 71121 Spectator Sports 14 391 337,500 71213 Zoos and Botanical Gardens 1 20 25,000 71219 Nature Parks and Other Similar Institutions 34 570 318,750 71311 Amusement and Theme Parks 6 2,095 200,000 71391 Golf Courses and Country Clubs 26 1,313 407,500 Total 5,702 130,534 110,563,750

Page 7 of 7

Exhibit 2: 5-Digit NAICS Codes Identified as Possible Generators of Wood Pallets and/or Clean WoodNAICS 5-Digit Code Title

Count of Businesses

Total Employees


11133 Noncitrus Fruit and Tree Nut Farming 1 4 25,000 11192 Cotton Farming 1 10 6,250 11199 All Other Crop Farming 2 13 26,250 11212 Dairy Cattle and Milk Production 2 80 75,000 11239 Other Poultry Production 1 2 6,250 11421 Hunting and Trapping 1 1 6,250 11511 Support Activities for Crop Production 3 8 56,250 11521 Support Activities for Animal Production 11 139 38,750 11531 Support Activities for Forestry 5 45 87,500 21111 Oil and Gas Extraction 11 39 275,000 21211 Coal Mining 4 98 81,250 21231 Stone Mining and Quarrying 14 215 331,250 21232 Sand, Gravel, Clay, and Ceramic and Refractory Minerals Mining and Quarrying 4 96 106,250 21239 Other Nonmetallic Mineral Mining and Quarrying 3 39 75,000 21311 Support Activities for Mining 1 4 25,000 22111 Electric Power Generation 7 61 156,250 22112 Electric Power Transmission, Control, and Distribution 13 7,090 425,000 22121 Natural Gas Distribution 6 471 118,750 22131 Water Supply and Irrigation Systems 5 39 106,250 33122 Rolling and Drawing of Purchased Steel 3 73 75,000 33131 Alumina and Aluminum Production and Processing 1 5 25,000 33142 Copper Rolling, Drawing, Extruding, and Alloying 1 6 25,000 33151 Ferrous Metal Foundries 4 719 150,000 33152 Nonferrous Metal Foundries 5 103 150,000 33211 Forging and Stamping 7 254 206,250 33242 Metal Tank (Heavy Gauge) Manufacturing 2 199 100,000 33243 Metal Can, Box, and Other Metal Container (Light Gauge) Manufacturing 10 258 281,250 33281 Coating, Engraving, Heat Treating, and Allied Activities 33 365 687,500 33312 Construction Machinery Manufacturing 10 173 300,000 33329 Other Industrial Machinery Manufacturing 24 907 725,000 33331 Commercial and Service Industry Machinery Manufacturing 22 482 568,750

Page 1 of 11


Count of Businesses

Total Employees


33341 Ventilation, Heating, Air-Conditioning, and Commercial Refrigeration Equipment Manufacturing 14 532 456,250 33351 Metalworking Machinery Manufacturing 18 895 506,250 33361 Engine, Turbine, and Power Transmission Equipment Manufacturing 9 999 281,250 33391 Pump and Compressor Manufacturing 9 190 256,250 33392 Material Handling Equipment Manufacturing 10 515 300,000 33399 All Other General Purpose Machinery Manufacturing 31 845 818,750 33621 Motor Vehicle Body and Trailer Manufacturing 5 128 156,250 42311 Automobile and Other Motor Vehicle Merchant Wholesalers 8 386 206,250 42322 Home Furnishing Merchant Wholesalers 28 294 687,500 42381 Construction and Mining (except Oil Well) Machinery and Equipment Merchant Wholesalers 45 6,944 1,250,000 42511 Business to Business Electronic Markets 2 2 12,500 42512 Wholesale Trade Agents and Brokers 93 1,519 1,650,000 44111 New Car Dealers 99 5,754 3,400,000 44112 Used Car Dealers 66 925 1,650,000 44121 Recreational Vehicle Dealers 5 149 75,000 44122 Motorcycle, Boat, and Other Motor Vehicle Dealers 65 480 500,000 44131 Automotive Parts and Accessories Stores 154 1,472 1,006,250 44132 Tire Dealers 93 938 625,000 44313 Camera and Photographic Supplies Stores 14 114 87,500 44512 Convenience Stores 97 1,041 465,000 44521 Meat Markets 6 59 37,500 44522 Fish and Seafood Markets 3 37 13,750 44523 Fruit and Vegetable Markets 2 16 7,500 44529 Other Specialty Food Stores 48 291 300,000 44531 Beer, Wine, and Liquor Stores 13 173 71,250 44611 Pharmacies and Drug Stores 162 2,624 3,906,250 44612 Cosmetics, Beauty Supplies, and Perfume Stores 40 400 250,000 44613 Optical Goods Stores 39 239 243,750 44619 Other Health and Personal Care Stores 88 746 637,500 44719 Other Gasoline Stations 62 573 77,500 44811 Men's Clothing Stores 60 364 375,000

Page 2 of 11


Count of Businesses

Total Employees


44812 Women's Clothing Stores 109 734 681,250 44813 Children's and Infants' Clothing Stores 50 375 1,118,750 44814 Family Clothing Stores 116 2,417 2,893,750 44815 Clothing Accessories Stores 53 178 368,750 44819 Other Clothing Stores 137 699 1,168,750 44821 Shoe Stores 124 1,053 818,750 44831 Jewelry Stores 43 520 223,750 44832 Luggage and Leather Goods Stores 12 113 281,250 45111 Sporting Goods Stores 109 1,114 681,250 45112 Hobby, Toy, and Game Stores 56 536 350,000 45113 Sewing, Needlework, and Piece Goods Stores 38 148 237,500 45114 Musical Instrument and Supplies Stores 38 244 237,500 45121 Book Stores and News Dealers 46 825 363,750 45122 Prerecorded Tape, Compact Disc, and Record Stores 7 197 72,500 45211 Department Stores 109 11,834 5,450,000 45299 All Other General Merchandise Stores 52 2,084 422,500 45311 Florists 19 253 103,750 45321 Office Supplies and Stationery Stores 53 1,171 500,000 45322 Gift, Novelty, and Souvenir Stores 97 855 606,250 45331 Used Merchandise Stores 57 747 400,000 45391 Pet and Pet Supplies Stores 30 342 187,500 45392 Art Dealers 25 111 156,250 45393 Manufactured (Mobile) Home Dealers 1 6 1,250 45399 All Other Miscellaneous Store Retailers 140 840 870,000 45411 Electronic Shopping and Mail-Order Houses 13 56 212,500 45421 Vending Machine Operators 30 177 187,500 45431 Fuel Dealers 2 4 12,500 45439 Other Direct Selling Establishments 60 2,369 1,362,500 48511 Urban Transit Systems 1 850 50,000 48521 Interurban and Rural Bus Transportation 4 23 100,000 48531 Taxi Service 11 468 351,250

Page 3 of 11


Count of Businesses

Total Employees


48532 Limousine Service 44 260 275,000 48541 School and Employee Bus Transportation 1 30 6,250 48551 Charter Bus Industry 20 334 456,250 48599 Other Transit and Ground Passenger Transportation 37 309 325,000 48611 Pipeline Transportation of Crude Oil 3 11 37,500 48721 Scenic and Sightseeing Transportation, Water 11 277 150,000 48799 Scenic and Sightseeing Transportation, Other 1 5 6,250 48833 Navigational Services to Shipping 2 5 31,250 48841 Motor Vehicle Towing 11 161 63,750 48851 Freight Transportation Arrangement 77 778 656,250 48899 Other Support Activities for Transportation 4 29 81,250 49111 Postal Service 42 808 1,075,000 49211 Couriers and Express Delivery Services 34 460 775,000 51111 Newspaper Publishers 33 2,387 293,750 51112 Periodical Publishers 50 1,329 1,168,750 51113 Book Publishers 17 795 375,000 51114 Directory and Mailing List Publishers 6 43 37,500 51119 Other Publishers 58 802 493,750 51121 Software Publishers 6 265 175,000 51211 Motion Picture and Video Production 96 607 643,750 51212 Motion Picture and Video Distribution 3 5 18,750 51213 Motion Picture and Video Exhibition 25 413 675,000 51223 Music Publishers 7 20 43,750 51224 Sound Recording Studios 30 84 187,500 51229 Other Sound Recording Industries 15 308 181,250 51511 Radio Broadcasting 37 1,147 221,250 51512 Television Broadcasting 15 1,086 512,500 51521 Cable and Other Subscription Programming 12 553 400,000 51711 Wired Telecommunications Carriers 55 1,688 1,487,500 51721 Wireless Telecommunications Carriers (except Satellite) 175 1,514 3,875,000 51791 Other Telecommunications 55 648 750,000

Page 4 of 11


Count of Businesses

Total Employees


51799 49 430 1,075,000 51821 Data Processing, Hosting, and Related Services 86 822 1,881,250 51911 News Syndicates 4 16 62,500 51912 Libraries and Archives 36 1,004 925,000 51919 All Other Information Services 26 139 162,500 52211 Commercial Banking 318 3,224 2,031,250 52212 Savings Institutions 2 8 12,500 52213 Credit Unions 51 566 318,750 52229 Other Nondepository Credit Intermediation 622 7,590 5,131,250 52232 Financial Transactions Processing, Reserve, and Clearinghouse Activities 16 113 70,000 52239 Other Activities Related to Credit Intermediation 2 6 12,500 52311 Investment Banking and Securities Dealing 32 3,130 375,000 52312 Securities Brokerage 32 623 375,000 52314 Commodity Contracts Brokerage 7 45 118,750 52391 Miscellaneous Intermediation 54 347 475,000 52392 Portfolio Management 17 115 106,250 52393 Investment Advice 358 2,002 2,281,250 52399 All Other Financial Investment Activities 15 60 225,000 52411 Direct Life, Health, and Medical Insurance Carriers 27 195 681,250 52412 Direct Insurance (except Life, Health, and Medical) Carriers 21 177 477,500 52421 Insurance Agencies and Brokerages 213 16,988 2,193,750 52429 Other Insurance Related Activities 14 274 106,250 52511 Pension Funds 20 219 481,250 52593 2 56 50,000 52599 Other Financial Vehicles 3 13 18,750 53111 Lessors of Residential Buildings and Dwellings 498 2,475 3,375,000 53112 Lessors of Nonresidential Buildings (except Miniwarehouses) 54 462 1,318,750 53113 Lessors of Miniwarehouses and Self-Storage Units 99 395 4,950,000 53119 Lessors of Other Real Estate Property 1 10 6,250 53121 Offices of Real Estate Agents and Brokers 312 8,355 3,577,500 53131 Real Estate Property Managers 39 558 191,250

Page 5 of 11


Count of Businesses

Total Employees


53132 Offices of Real Estate Appraisers 15 161 68,750 53139 Other Activities Related to Real Estate 17 258 96,250 53211 Passenger Car Rental and Leasing 50 779 356,250 53212 Truck, Utility Trailer, and RV (Recreational Vehicle) Rental and Leasing 65 546 508,750 53221 Consumer Electronics and Appliances Rental 19 93 118,750 53222 Formal Wear and Costume Rental 2 18 12,500 53223 Video Tape and Disc Rental 41 391 256,250 53229 Other Consumer Goods Rental 44 358 275,000 53231 General Rental Centers 47 654 381,250 53241 Construction, Transportation, Mining, and Forestry Machinery and Equipment Rental and Leasing 15 114 93,750 53242 Office Machinery and Equipment Rental and Leasing 8 53 125,000 53249 Other Commercial and Industrial Machinery and Equipment Rental and Leasing 29 395 181,250 53311 Lessors of Nonfinancial Intangible Assets (except Copyrighted Works) 5 27 31,250 54111 Offices of Lawyers 122 2,745 647,500 54119 Other Legal Services 39 251 208,750 54121 Accounting, Tax Preparation, Bookkeeping, and Payroll Services 120 3,719 405,000 54131 Architectural Services 80 2,710 615,000 54132 Landscape Architectural Services 29 764 688,750 54133 Engineering Services 234 3,823 1,637,500 54134 Drafting Services 8 23 50,000 54135 Building Inspection Services 11 27 68,750 54136 Geophysical Surveying and Mapping Services 1 15 25,000 54137 Surveying and Mapping (except Geophysical) Services 23 326 38,750 54138 Testing Laboratories 20 199 425,000 54141 Interior Design Services 225 621 1,450,000 54143 Graphic Design Services 11 2,068 82,500 54149 Other Specialized Design Services 37 118 231,250 54151 Computer Systems Design and Related Services 317 3,428 4,562,500 54161 Management Consulting Services 475 7,937 3,625,000 54162 Environmental Consulting Services 1 15 25,000 54169 Other Scientific and Technical Consulting Services 59 619 493,750

Page 6 of 11


Count of Businesses

Total Employees


54171 Research and Development in the Physical, Engineering, and Life Sciences 98 1,300 806,250 54172 Research and Development in the Social Sciences and Humanities 16 58 325,000 54181 Advertising Agencies 140 1,010 962,500 54182 Public Relations Agencies 19 149 368,750 54184 Media Representatives 8 131 201,250 54185 Display Advertising 27 229 650,000 54186 Direct Mail Advertising 79 826 1,693,750 54187 Advertising Material Distribution Services 56 753 1,287,500 54189 Other Services Related to Advertising 101 511 1,762,500 54191 Marketing Research and Public Opinion Polling 35 463 781,250 54192 Photographic Services 23 1,019 128,750 54193 Translation and Interpretation Services 28 163 218,750 54194 Veterinary Services 51 994 243,750 54199 All Other Professional, Scientific, and Technical Services 168 692 1,425,000 55111 Management of Companies and Enterprises 33 11,410 818,750 56111 Office Administrative Services 73 408 1,343,750 56131 Employment Placement Agencies and Executive Search Services 102 2,237 752,500 56132 Temporary Help Services 53 900 1,193,750 56133 Professional Employer Organizations 23 356 575,000 56142 Telephone Call Centers 30 821 231,250 56143 Business Service Centers 30 241 187,500 56144 Collection Agencies 22 535 512,500 56145 Credit Bureaus 6 60 150,000 56149 Other Business Support Services 60 460 512,500 56151 Travel Agencies 17 337 86,250 56152 Tour Operators 9 35 168,750 56159 Other Travel Arrangement and Reservation Services 15 105 150,000 56161 Investigation, Guard, and Armored Car Services 83 4,083 1,218,750 56162 Security Systems Services 12 80 201,250 56171 Exterminating and Pest Control Services 30 693 162,500 56172 Janitorial Services 222 1,714 1,431,250

Page 7 of 11


Count of Businesses

Total Employees


56173 Landscaping Services 62 2,150 337,500 56174 Carpet and Upholstery Cleaning Services 134 495 837,500 56179 Other Services to Buildings and Dwellings 6 35 37,500 56199 All Other Support Services 132 1,391 1,000,000 56211 Waste Collection 34 639 337,500 56221 Waste Treatment and Disposal 14 329 131,250 56291 Remediation Services 7 175 87,500 56292 Materials Recovery Facilities 2 14 12,500 56299 All Other Waste Management Services 6 120 156,250 61111 Elementary and Secondary Schools 280 21,640 12,625,000 61121 Junior Colleges 3 164 100,000 61131 Colleges, Universities, and Professional Schools 38 3,642 1,318,750 61141 Business and Secretarial Schools 15 179 287,500 61142 Computer Training 14 90 293,750 61143 Professional and Management Development Training 18 123 112,500 61151 Technical and Trade Schools 18 112 261,250 61161 Fine Arts Schools 72 522 493,750 61162 Sports and Recreation Instruction 50 342 312,500 61163 Language Schools 4 50 25,000 61169 All Other Schools and Instruction 58 441 362,500 61171 Educational Support Services 61 518 381,250 62111 Offices of Physicians 289 4,400 1,740,000 62121 Offices of Dentists 68 748 200,000 62131 Offices of Chiropractors 13 102 21,250 62132 Offices of Optometrists 21 208 76,250 62133 Offices of Mental Health Practitioners (except Physicians) 7 36 42,500 62134 Offices of Physical, Occupational and Speech Therapists, and Audiologists 24 242 85,000 62139 Offices of All Other Health Practitioners 23 310 88,750 62141 Family Planning Centers 3 23 56,250 62149 Other Outpatient Care Centers 62 1,519 707,500 62151 Medical and Diagnostic Laboratories 41 566 300,000

Page 8 of 11


Count of Businesses

Total Employees


62161 Home Health Care Services 84 2,507 2,231,250 62191 Ambulance Services 3 227 62,500 62199 All Other Ambulatory Health Care Services 115 1,365 806,250 62221 Psychiatric and Substance Abuse Hospitals 22 550 225,000 62231 Specialty (except Psychiatric and Substance Abuse) Hospitals 1 5 6,250 62419 Other Individual and Family Services 275 6,530 6,687,500 62421 Community Food Services 1 24 25,000 62422 Community Housing Services 3 132 100,000 62431 Vocational Rehabilitation Services 64 1,512 1,531,250 62441 Child Day Care Services 334 5,032 2,131,250 71111 Theater Companies and Dinner Theaters 12 77 75,000 71113 Musical Groups and Artists 3 38 75,000 71119 Other Performing Arts Companies 7 172 162,500 71131 Promoters of Performing Arts, Sports, and Similar Events with Facilities 50 480 475,000 71132 Promoters of Performing Arts, Sports, and Similar Events without Facilities 11 110 237,500 71141 Agents and Managers for Artists, Athletes, Entertainers, and Other Public Figures 15 58 93,750 71151 Independent Artists, Writers, and Performers 36 402 406,250 71211 Museums 32 391 287,500 71212 Historical Sites 2 6 12,500 71312 Amusement Arcades 2 7 12,500 71329 Other Gambling Industries 1 3 6,250 71392 Skiing Facilities 1 6 6,250 71393 Marinas 1 12 6,250 71394 Fitness and Recreational Sports Centers 187 1,754 3,993,750 71395 Bowling Centers 7 188 200,000 71399 All Other Amusement and Recreation Industries 37 312 406,250 72111 Hotels (except Casino Hotels) and Motels 215 7,237 5,918,750 72119 Other Traveler Accommodation 20 152 368,750 72121 RV (Recreational Vehicle) Parks and Recreational Camps 11 119 232,500 72131 Rooming and Boarding Houses 12 65 262,500 72211 Full-Service Restaurants 93 1,809 566,250

Page 9 of 11


Count of Businesses

Total Employees


72221 Limited-Service Eating Places 1,381 33,185 8,316,250 72231 Food Service Contractors 8 235 50,000 72232 Caterers 58 832 237,500 72241 Drinking Places (Alcoholic Beverages) 51 905 308,750 81111 Automotive Mechanical and Electrical Repair and Maintenance 146 1,886 802,500 81112 Automotive Body, Paint, Interior, and Glass Repair 162 1,117 1,112,500 81119 Other Automotive Repair and Maintenance 43 685 233,750 81121 Electronic and Precision Equipment Repair and Maintenance 46 543 667,500

81131 Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance 20 587 345,000 81141 Home and Garden Equipment and Appliance Repair and Maintenance 13 85 81,250 81142 Reupholstery and Furniture Repair 2 14 7,500 81149 Other Personal and Household Goods Repair and Maintenance 20 121 162,500 81211 Hair, Nail, and Skin Care Services 269 3,023 666,250 81219 Other Personal Care Services 29 470 151,250 81221 Funeral Homes and Funeral Services 37 256 231,250 81222 Cemeteries and Crematories 16 145 100,000 81231 Coin-Operated Laundries and Drycleaners 7 35 43,750 81232 Drycleaning and Laundry Services (except Coin-Operated) 110 910 706,250 81233 Linen and Uniform Supply 8 774 325,000 81291 Pet Care (except Veterinary) Services 6 72 17,500 81292 Photofinishing 6 94 37,500 81293 Parking Lots and Garages 31 691 500,000 81299 All Other Personal Services 13 65 71,250 81311 Religious Organizations 1,032 6,582 21,025,000 81321 Grantmaking and Giving Services 15 65 112,500 81331 Social Advocacy Organizations 182 2,690 1,468,750 81341 Civic and Social Organizations 150 2,192 1,462,500 81391 Business Associations 128 880 843,750 81392 Professional Organizations 2 4 31,250 81393 Labor Unions and Similar Labor Organizations 19 61 118,750

Page 10 of 11


Count of Businesses

Total Employees


81399 Other Similar Organizations (except Business, Professional, Labor, and Political Organizations) 18 75 412,500 92111 Executive Offices 8 70 200,000 92112 Legislative Bodies 193 5,866 2,431,250 92113 Public Finance Activities 16 567 275,000 92119 Other General Government Support 28 365 712,500 92211 Courts 13 277 350,000 92212 Police Protection 41 4,638 1,625,000 92213 Legal Counsel and Prosecution 6 283 175,000 92214 Correctional Institutions 5 197 118,750 92215 Parole Offices and Probation Offices 4 206 100,000 92216 Fire Protection 61 4,544 1,556,250 92219 Other Justice, Public Order, and Safety Activities 1 5 6,250 92311 Administration of Education Programs 1 3 25,000 92312 Administration of Public Health Programs 9 635 275,000 92313 Administration of Human Resource Programs (except Education, Public Health, and Veterans' Affairs Programs) 11 145 275,000 92314 Administration of Veterans' Affairs 1 4 25,000 92411 Administration of Air and Water Resource and Solid Waste Management Programs 6 712 225,000 92412 Administration of Conservation Programs 2 9 12,500 92512 Administration of Urban Planning and Community and Rural Development 3 14 75,000 92611 Administration of General Economic Programs 8 261 93,750 92612 Regulation and Administration of Transportation Programs 29 1,763 900,000 92613 Regulation and Administration of Communications, Electric, Gas, and Other Utilities 10 399 325,000 92614 Regulation of Agricultural Marketing and Commodities 5 27 31,250 92615 Regulation, Licensing, and Inspection of Miscellaneous Commercial Sectors 2 19 50,000 92811 National Security 29 273 675,000 92812 International Affairs 4 22 100,000 Total 18,857 359,781 234,711,250

Page 11 of 11

Exhibit 3: 5-Digit NAICS Codes for Mecklenburg County Businesses not Surveyed (Unlikely Generators)

NAICS 5-Digit Code Title

Count of Businesses

Total Employees


11142 Nursery and Floriculture Production 6 17 7,50011199 All Other Crop Farming 7 15 8,75011521 Support Activities for Animal Production 45 80 56,25031181 Bread and Bakery Product Manufacturing 37 128 46,25031213 Wineries 4 12 5,00032412 Asphalt Paving, Roofing, and Saturated Materials Manufacturing 1 3 1,25032621 Tire Manufacturing 3 12 3,75033232 Ornamental and Architectural Metal Products Manufacturing 1 1 1,25033329 Other Industrial Machinery Manufacturing 7 17 8,75033461 Manufacturing and Reproducing Magnetic and Optical Media 1 1 1,25033911 Medical Equipment and Supplies Manufacturing 18 42 22,50042312 Motor Vehicle Supplies and New Parts Merchant Wholesalers 1 1 1,25042314 Motor Vehicle Parts (Used) Merchant Wholesalers 22 66 27,50042339 Other Construction Material Merchant Wholesalers 31 98 38,75042472 Petroleum and Petroleum Products Merchant Wholesalers (except Bulk Stations and Terminals) 7 11 8,75042493 Flower, Nursery Stock, and Florists' Supplies Merchant Wholesalers 1 2 1,25044111 New Car Dealers 3 3 3,75044112 Used Car Dealers 96 166 120,00044121 Recreational Vehicle Dealers 4 4 5,00044229 Other Home Furnishings Stores 29 69 36,25044311 Appliance, Television, and Other Electronics Stores 56 110 70,00044313 Camera and Photographic Supplies Stores 1 1 1,25044421 Outdoor Power Equipment Stores 11 34 13,75044422 Nursery, Garden Center, and Farm Supply Stores 48 149 60,00044511 Supermarkets and Other Grocery (except Convenience) Stores 130 387 162,50044512 Convenience Stores 175 506 218,75044521 Meat Markets 6 14 7,50044522 Fish and Seafood Markets 11 23 13,75044523 Fruit and Vegetable Markets 12 35 15,00044529 Other Specialty Food Stores 8 14 10,00044531 Beer, Wine, and Liquor Stores 31 102 38,750

Page 1 of 6



Count of Businesses

Total Employees


44612 Cosmetics, Beauty Supplies, and Perfume Stores 65 106 81,25044613 Optical Goods Stores 10 17 12,50044619 Other Health and Personal Care Stores 17 32 21,25044719 Other Gasoline Stations 68 217 85,00044812 Women's Clothing Stores 34 54 42,50044831 Jewelry Stores 99 265 123,75045111 Sporting Goods Stores 36 65 45,00045113 Sewing, Needlework, and Piece Goods Stores 1 1 1,25045121 Book Stores and News Dealers 22 32 27,50045122 Prerecorded Tape, Compact Disc, and Record Stores 26 68 32,50045299 All Other General Merchandise Stores 62 140 77,50045311 Florists 79 184 98,75045322 Gift, Novelty, and Souvenir Stores 89 152 111,25045331 Used Merchandise Stores 90 149 112,50045391 Pet and Pet Supplies Stores 7 8 8,75045392 Art Dealers 43 69 53,75045393 Manufactured (Mobile) Home Dealers 5 22 6,25045399 All Other Miscellaneous Store Retailers 87 138 108,75045439 Other Direct Selling Establishments 1 1 1,25048121 Nonscheduled Air Transportation 1 2 1,25048531 Taxi Service 18 54 22,50048532 Limousine Service 20 28 25,00048599 Other Transit and Ground Passenger Transportation 4 6 5,00048721 Scenic and Sightseeing Transportation, Water 3 5 3,75048799 Scenic and Sightseeing Transportation, Other 4 6 5,00048841 Motor Vehicle Towing 69 162 86,25051219 Postproduction Services and Other Motion Picture and Video Industries 1 1 1,25051511 Radio Broadcasting 10 25 12,50052229 Other Nondepository Credit Intermediation 7 14 8,75052232 Financial Transactions Processing, Reserve, and Clearinghouse Activities 54 118 67,50052311 Investment Banking and Securities Dealing 32 63 40,000

Page 2 of 6



Count of Businesses

Total Employees


52312 Securities Brokerage 10 18 12,50052313 Commodity Contracts Dealing 1 3 1,25052391 Miscellaneous Intermediation 5 8 6,25052412 Direct Insurance (except Life, Health, and Medical) Carriers 60 135 75,00052413 Reinsurance Carriers 3 13 3,75052421 Insurance Agencies and Brokerages 627 1,659 783,75052429 Other Insurance Related Activities 43 148 53,75053119 Lessors of Other Real Estate Property 18 33 22,50053121 Offices of Real Estate Agents and Brokers 940 3,139 1,175,00053131 Real Estate Property Managers 29 100 36,25053132 Offices of Real Estate Appraisers 72 160 90,00053139 Other Activities Related to Real Estate 80 147 100,00053211 Passenger Car Rental and Leasing 13 22 16,25053212 Truck, Utility Trailer, and RV (Recreational Vehicle) Rental and Leasing 12 24 15,00053222 Formal Wear and Costume Rental 9 27 11,25054111 Offices of Lawyers 1,182 2,714 1,477,50054119 Other Legal Services 31 107 38,75054121 Accounting, Tax Preparation, Bookkeeping, and Payroll Services 503 1,284 628,75054131 Architectural Services 149 434 186,25054132 Landscape Architectural Services 64 166 80,00054133 Engineering Services 52 72 65,00054137 Surveying and Mapping (except Geophysical) Services 25 88 31,25054143 Graphic Design Services 115 205 143,75054161 Management Consulting Services 263 453 328,75054184 Media Representatives 6 20 7,50054192 Photographic Services 171 285 213,75054194 Veterinary Services 32 106 40,00056131 Employment Placement Agencies and Executive Search Services 170 560 212,50056132 Temporary Help Services 2 4 2,50056141 Document Preparation Services 9 12 11,25056149 Other Business Support Services 20 41 25,000

Page 3 of 6



Count of Businesses

Total Employees


56151 Travel Agencies 104 283 130,00056159 Other Travel Arrangement and Reservation Services 1 1 1,25056161 Investigation, Guard, and Armored Car Services 18 27 22,50056162 Security Systems Services 58 109 72,50056171 Exterminating and Pest Control Services 53 154 66,25056173 Landscaping Services 349 764 436,25056179 Other Services to Buildings and Dwellings 1 2 1,25056211 Waste Collection 10 13 12,50056221 Waste Treatment and Disposal 3 5 3,75056292 Materials Recovery Facilities 1 1 1,25056299 All Other Waste Management Services 3 5 3,75061143 Professional and Management Development Training 11 11 13,75061151 Technical and Trade Schools 42 106 52,50061161 Fine Arts Schools 25 28 31,25061162 Sports and Recreation Instruction 65 107 81,25061163 Language Schools 1 2 1,25061169 All Other Schools and Instruction 18 24 22,50061171 Educational Support Services 4 5 5,00062111 Offices of Physicians 525 1,602 656,25062121 Offices of Dentists 327 1,301 408,75062131 Offices of Chiropractors 148 384 185,00062132 Offices of Optometrists 48 166 60,00062133 Offices of Mental Health Practitioners (except Physicians) 42 86 52,50062134 Offices of Physical, Occupational and Speech Therapists, and Audiologists 53 152 66,25062139 Offices of All Other Health Practitioners 244 635 305,00062149 Other Outpatient Care Centers 22 70 27,50062191 Ambulance Services 1 1 1,25062441 Child Day Care Services 69 96 86,25071113 Musical Groups and Artists 5 14 6,25071119 Other Performing Arts Companies 37 59 46,25071131 Promoters of Performing Arts, Sports, and Similar Events with Facilities 1 2 1,250

Page 4 of 6



Count of Businesses

Total Employees


71151 Independent Artists, Writers, and Performers 61 78 76,25071212 Historical Sites 2 4 2,50071312 Amusement Arcades 6 10 7,50071329 Other Gambling Industries 1 2 1,25071391 Golf Courses and Country Clubs 1 1 1,25071393 Marinas 19 41 23,75071399 All Other Amusement and Recreation Industries 19 22 23,75072121 RV (Recreational Vehicle) Parks and Recreational Camps 2 5 2,50072211 Full-Service Restaurants 15 57 18,75072221 Limited-Service Eating Places 391 1,233 488,75072231 Food Service Contractors 15 42 18,75072232 Caterers 35 87 43,75072241 Drinking Places (Alcoholic Beverages) 68 212 85,00081111 Automotive Mechanical and Electrical Repair and Maintenance 334 821 417,50081119 Other Automotive Repair and Maintenance 106 274 132,50081121 Electronic and Precision Equipment Repair and Maintenance 95 182 118,750

81131 Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance 34 83 42,50081141 Home and Garden Equipment and Appliance Repair and Maintenance 48 88 60,00081142 Reupholstery and Furniture Repair 41 66 51,25081143 Footwear and Leather Goods Repair 19 26 23,75081149 Other Personal and Household Goods Repair and Maintenance 76 146 95,00081211 Hair, Nail, and Skin Care Services 974 2,422 1,217,50081219 Other Personal Care Services 206 423 257,50081222 Cemeteries and Crematories 10 33 12,50081231 Coin-Operated Laundries and Drycleaners 30 47 37,50081232 Drycleaning and Laundry Services (except Coin-Operated) 161 277 201,25081291 Pet Care (except Veterinary) Services 61 120 76,25081292 Photofinishing 5 6 6,25081299 All Other Personal Services 80 153 100,00081394 Political Organizations 3 7 3,750

Page 5 of 6



Count of Businesses

Total Employees


81399 Other Similar Organizations (except Business, Professional, Labor, and Political Organizations) 1 1 1,25099999 31 734 850,000NA Not available [3] 1,598 7,277 38,320,000Total 13,430 37,709 53,921,250

Page 6 of 6


APPENDIX E

Hauler Survey Responses

Both Both Both Both CommercialComplete Complete Complete Complete Complete

Commercial Hauler Survey Responses for Question 1 through 81 2 4 5 12

Survey ResponsesCompleted Survey 1 1 1 1 1

Declined to Complete SurveyFailed to Return Messages

Busy/Disconnected/Fax NumberServices Provided

Dumpster 1 1 1 1 1Roll-Off 1 1 1 1 1

Residential Only1 Do any of your current front load customers place clean wood or pallets in their

dumpsters?Wood Pallets 1 1Clean Wood

Both Wood Pallets and Clean Wood 1Neither 1 1

Don't knowDo not provide dumpster service

2If some of your current front load customers place pallets in the dumpsters,, does collecting wood pallets present any collection problems?

YesNo 1 1 1

Not Applicable 1 12 If some of your current front load customers place clean wood in the dumpsters,

does collecting clean wood present any collection problems?YesNo 1 1 1

Not Applicable 1 13 Please estimate the percentage of your Front Load Customers that dispose of

wood pallets or clean wood in their dumpsters.Wood Pallets 0% 5-10% 10% 1%Clean Wood 0% >5% 0% >1%

Don't knowNot Applicable 1

3 Please estimate the percentage of your Roll-Off Customers that dispose of wood pallets or clean wood in their roll-off containers.

Wood Pallets 100% 20% > or = 10% 80% 1%Clean Wood 0% 75% > or = 10% 70% >1%

Don't knowNot Applicable

Page 1 of 3


4 Typically, what types of Front Load customers are the major generators of pallets? Of clean wood?

Wood Pallets Trucking Warehouses Warehouses Warehouses It is randomClean Wood Supply Houses Wood Shops/ Frame Shops NA It is random

Not Applicable4 Typically, what types of Roll-Off customers are the major generators of pallets?

Of clean wood?Wood Pallets Construction Plant and Industry Warehouse Homebuilders It is random

Clean Wood ConstructionResidential New

Construction Warehouse Homebuilders It is randomNot Applicable

5 Do you collect recyclables from any of your customers?Yes 1 1 1 1 1No

6 Please estimate what percentage of your current Front Load Customers have recycling collection of the following recyclable materials.

Old Corrugated Cardboard 100% 15-20% 10% see Table 2 65%Wood Pallets <1%Clean Wood <1%

Gypsum WallboardOther- White Paper 35%

Other- Aluminum Cans 0.016 Please estimate what percentage of your current Roll-Off Customers have

recycling collection of the following recyclable materials.

Old Corrugated Cardboard 10% 10% 40% 80%Wood Pallets 15% 5%Clean Wood 20% <5%

Gypsum Wallboard 25%Other- Newspaper 10%

Other- Concrete 30%Other- Plastic 20%Other- Metal 7% 20%

Other- Aluminum Cans >1%7 If you provide Wood Pallet recycling collection services, please indicate where

you take the Wood Pallets for recycling or reuse.

Name 4 Locations but could only think of

Custom Pallets Custom Pallet LA PalletsLocation Grand Street Charlotte Charlotte

Not Applicable 17 If you provide Clean Wood recycling collection services, please indicate where

you take the Clean Wood for recycling or reuse.

Name Foxhole Landfill Foxhole Landfill LA PalletsLocation Charlotte

Not Applicable 1

Page 2 of 3


8 What do you believe are the reasons your customers do not recycle Wood Pallets ? Please check all that apply.

Lack of storage placeCost/2nd dumpster 1 1

Small volume generator 1Service not available

Lack of recycling knowledge 1 1

OtherNot enough

quantity.Customers do not need

the service.Not Applicable 1

8 What do you believe are the reasons your customers do not recycle Clean Wood ? Please check all that apply.

Lack of storage place 1Cost/2nd dumpster 1 1 1

Small volume generator 1Service not available

Lack of recycling knowledge 1

OtherNot enough

quantity.Customers do not need

the service.Not Applicable 1

Answers for Questions 9 and 10 and other comments are located in Table 2.

Page 3 of 3

1

Commercial Hauler Survey Responses for Question 9 and 10 and Other Comments

9. What steps do you recommend the County take to ensure compliance with the 2009 landfill ban on wood pallets? (1) Facility should charge less to take pallets. (2) County needs to develop a MRF that can sort separate and has equipment that can grind and mulch the wood pallets. According to the Hauler, the equipment to grind and mulch costs a half million dollars. (4) Hauler stated that this is up to the County. (5) Hauler recommends the County find some where else to take them. (12) Hauler doesn't know what the County should do. County should just have haulers be careful. 10. What steps would you take to prevent customers from putting wood pallets in their dumpster? (1) Hauler will inform customers; however, Hauler will not fine customers for noncompliance. Hauler is opposed to fines. Hauler will just stop accepting wood pallets. (2) Hauler will tell his customers they are not allowed to put wood pallets in their dumpsters. In addition, Hauler will fine customers $5 per pallet. (4) Hauler will inform the customers through the Hauler's sales department. (5) Haul will not haul the dumpster if there are wood pallets in the dumpster. (12) Hauler will no take the wood pallets. Hauler will recycle them. General Comments: (2) The only way this will work is if you build a MRF. Hauler has some ideas and some plans that they need the County's help with to make it work. (2) No one knows what to do with wood pallets. Hauler believes the best option is grind the pallets and spray the material red and call it wood chips for new homes. However, the market got too costly and home builders are only interested in making the most money possible.

2

(12) Hauler only services commercial buildings. Comments About Specific Questions: 1. Do any of your current front load customers place clean wood or pallets in their dumpsters? (4) Hauler stated that it is hard to tell if there is clean wood but the Hauler is sure there is some. (12) Every now and then the Hauler's front load customers place wood pallets in their dumpsters. However, the wood pallets disposed by the Hauler's customers are usually very broken. According to the Hauler, wood pallets are placed in its dumpsters only 2-3 times per year. If a wood pallet is placed in the Hauler's dumpster, the Hauler pulls the pallet out and a private contractor, Johnny Brown, collects and repairs the pallets. 2. If some of your current front load customers place clean wood or pallets in the dumpsters, does collecting clean wood or pallets present any collection problems? (5) Hauler stated that collecting wood pallets is not a problem as long as the customer breaks the wood pallets down. 3. Please estimate the percentage of your customers that dispose of wood pallets or clean wood in their dumpsters or roll-off containers. (2) Hauler does a lot of temporary construction work. Wood pallets are a sore spot in this industry. (4) Hauler stated that the estimate is a wild guess. 5. Do you collect recyclables from any of your customers? (5) A private company empties and hauls OCC from the Hauler's front-end load customers. The private company provides OCC recycling to approximately 90% of Hauler's front-end load customers. 7. If you provide pallet and/or clean wood recycling collection services, please indicate where you take the clean wood or pallets for recycling or reuse.

3

(2) Hauler will provide recycling for roll-off customers only if they sign up for green project. Hauler quoted the cost of green project to a roll-off customer and the customer elected against it due to the cost. 8. What do you believe are the reasons your customers do not recycle pallets and clean wood? Please check all that apply. (2) Hauler is in the process of doing a recycling facility for wood pallets.

C&D C&D C&D C&DComplete Complete Complete Complete

Roll-off Hauler Survey Responses for Question 1 through 83 6 7 8

Survey ResponsesCompleted Survey 1 1 1 1



Dumpster 1 1 1Roll-Off 1 1 1 1


dumpsters?Wood Pallets 1Clean Wood

Both Wood Pallets and Clean Wood 1Neither 1

Don't knowDo not provide dumpster service 1


YesNo 1 1

Not Applicable 1 12 If some of your current front load customers place clean wood in the dumpsters,

does collecting clean wood present any collection problems?YesNo 1 1

Not Applicable 1 13 Please estimate the percentage of your Front Load Customers that dispose of

wood pallets or clean wood in their dumpsters.Wood Pallets 1%Clean Wood 100%

Don't know 1Not Applicable 1 1


Wood Pallets 20% 0%Clean Wood 100% 100%

Don't know 1Not Applicable 1

Page 1 of 6

Roll-off Hauler Survey Responses for Question 1 through 8

Survey ResponsesCompleted Survey



DumpsterRoll-Off


dumpsters?Wood PalletsClean Wood

Both Wood Pallets and Clean WoodNeither

Don't knowDo not provide dumpster service


YesNo

Not Applicable2 If some of your current front load customers place clean wood in the dumpsters,

does collecting clean wood present any collection problems?YesNo

Not Applicable3 Please estimate the percentage of your Front Load Customers that dispose of

wood pallets or clean wood in their dumpsters.Wood PalletsClean Wood



Wood PalletsClean Wood


C&D C&D C&D C&DComplete Complete Complete Complete

9 10 11 13

1 1 1 1

1 1 1 1

1 1 1 1

1 1 1 1

1 1 1 1

11 1 1

4% >5% 5%5% >5% 0%

1

Page 2 of 6



Wood Pallets Dellweb ConstructionClean Wood Dellweb Construction

Not Applicable 1 14 Typically, what types of Roll-Off customers are the major generators of pallets?

Of clean wood?Wood Pallets Construction NA

Clean Wood Construction New ConstructionNot Applicable 1

5 Do you collect recyclables from any of your customers?Yes 1 1No 1 1


Old Corrugated Cardboard

Provides OCC recycling but could

not estimate %Wood PalletsClean Wood

Gypsum WallboardOther- White Paper

Other- Aluminum Cans6 Please estimate what percentage of your current Roll-Off Customers have


Old Corrugated Cardboard

Provides OCC recycling but could

not estimate %Wood PalletsClean Wood

Gypsum WallboardOther- Newspaper

Other- ConcreteOther- PlasticOther- Metal 1%

Other- Aluminum Cans7 If you provide Wood Pallet recycling collection services, please indicate where


Name Location

Not Applicable 1 17 If you provide Clean Wood recycling collection services, please indicate where


Name Location

Not Applicable 1 1

Page 3 of 6



Wood PalletsClean Wood

Not Applicable4 Typically, what types of Roll-Off customers are the major generators of pallets?

Of clean wood?Wood Pallets

Clean WoodNot Applicable

5 Do you collect recyclables from any of your customers?YesNo


Old Corrugated CardboardWood PalletsClean Wood

Gypsum WallboardOther- White Paper

Other- Aluminum Cans6 Please estimate what percentage of your current Roll-Off Customers have


Old Corrugated CardboardWood PalletsClean Wood

Gypsum WallboardOther- Newspaper

Other- ConcreteOther- PlasticOther- Metal

Other- Aluminum Cans7 If you provide Wood Pallet recycling collection services, please indicate where


Name Location

Not Applicable7 If you provide Clean Wood recycling collection services, please indicate where


Name Location

Not Applicable

9 10 11 13

1 1

Commercial Warehouses Triad Homebuilders

Commercial Warehouses Triad NA Construction

1 11 1

<1%<1%<1%<1%

15%

5%

Metromont Natural Recycling Center

Charlotte1

Metromont Natural Recycling Center

Charlotte1

Page 4 of 6



Lack of storage placeCost/2nd dumpster

Small volume generatorService not available

Lack of recycling knowledge 1

Other

Customers send wood pallets back to where it came from

thus no need for recycling.

No time and not on their mind

Not Applicable 1 1 18 What do you believe are the reasons your customers do not recycle Clean Wood ?

Please check all that apply.Lack of storage place

Cost/2nd dumpster 1Small volume generator

Service not availableLack of recycling knowledge

Other

Customers send clean wood back to where it came from

thus no need for recycling.

Can't think for the customers. Space on the job site.

No market and no advantage to separating

wood clean wood.Not Applicable 1


Page 5 of 6





Lack of recycling knowledge

OtherNot Applicable

8 What do you believe are the reasons your customers do not recycle Clean Wood ? Please check all that apply.



Lack of recycling knowledge

OtherNot Applicable


9 10 11 13

1

1 1

Workers' don’t' care and they contaminate it. Convenience

1

11

1

Workers' don’t care and they contaminate it. Convenience Not and issue

Laziness. Companies do not want to recycle.

Page 6 of 6

1

Roll-off Hauler Survey Responses for Question 9 and 10 and Other Comments

9. What steps do you recommend the County take to ensure compliance with the 2009 landfill ban on wood pallets? (3) Hauler believes the County should keep their nose out of the hauler's and the customers' business. (6) Hauler stated that the County needs to set something up for wood pallets. (7) Hauler believes the County should make it more feasible for the people to recycle. (8) Hauler believes that a wood pallet landfill ban can be done but need to find a market for the wood pallets. County needs to do something to develop a market that can compete with landfill costs. (9) Hauler doesn't know what the County should do to ensure compliance. (10) Hauler recommends the County find private landfills that will take the wood pallets. (11) County should use mailings. 10. What steps would you take to prevent customers from putting wood pallets in their dumpster? (3) The Hauler does whatever the customers requires. Everything is market driven and if the market required wood pallet recycling then it would naturally occur. Therefore, more government is not required in this situation. (7) Hauler will back charge the customer or use other means. (8) County needs to look at markets such as generating power fuel and wood chips. County should look at New York. Hauler stated that New York burns the wood pallets with tires. According to the Hauler, it took New York 3 years to get power plant to look at it. It is worth it if you had market below landfill cost. (9) Hauler will not take any steps to prevent customers from putting wood pallets in their dumpsters. (10) Hauler can pass the cost along to the customers. (11) Hauler will use mailings.

2

General Comments: (6) Hauler is really excited about the wood pallet ban. Hauler was not aware of the ban prior to the survey. (9) County should lower landfill fees. (10) Hauler was not aware of new law prior to the survey. Hauler believes the problem is it will cost more. Wood recycling has never been a money maker for anyone and only makes sense to those who want to save the earth. Wood is a huge item. Comments About Specific Questions: 1. Do any of your current front load customers place clean wood or pallets in their dumpsters? (3) Hauler's customers do not throw away good pallets or wood. Hauler's customers throw away junk. (7) Hauler stated that customers dispose of wood pallets every now an then. As for clean wood, customers dispose of left over clean wood. 2. If some of your current front load customers place clean wood or pallets in the dumpsters, does collecting clean wood or pallets present any collection problems? (7) Even though Hauler answered no to the question, Hauler stated that the collection of wood pallets and clean wood wears and tears equipment and adds to disposal costs. (10) More like 1% 3. Please estimate the percentage of your customers that dispose of wood pallets or clean wood in their dumpsters or roll-off containers. (7) Wood pallets are not a big issue because the Hauler services construction sites a lot. (9) Clean wood that is disposed is cut up. 5. Do you collect recyclables from any of your customers? (6) Hauler use to provide recycling services but customers kept mixing garbage with the recyclables.

3

(7) Hauler just began green projects. 6. Please estimate what percentage of your current customers have recycling collection of the following recyclable materials. (10) Hauler has a customer who recycles wood pallets and clean wood. 8. What do you believe are the reasons your customers do not recycle pallets and clean wood? Please check all that apply. (7) Customer has done recycling; however, the Hauler's customer base isn't the type for recycling.


APPENDIX F

Mecklenburg County C&D Waste Characterization Results

Mecklenburg County C&D Composition Study 3-1

3. RESULTS

INTRODUCTION

This section presents the results of the Mecklenburg County construction and demolition (C&D) waste composition study. Further, this section describes the underlying assumptions, analytical techniques, and statistical analysis that was performed to generate the results. Specifically, this section discusses:

Volume-to-Weight Conversion,

Statistical Measures, and

Results.

VOLUME-TO-WEIGHT CONVERSION

As described in the Methodology section, all of the field data collection relied on volumetric estimates of the composition of each incoming load of C&D waste that was representatively selected for sampling. For each load, the container volume, percent full, and estimated fraction of each C&D material category was estimated and recorded. While the methodology used for visual surveying was performed consistently and accurately, and relied on quantitative measurements for some portion of the estimate, in practice there is potential for error to be introduced because certain steps of visual characterization are, by nature, somewhat imprecise. For example, two well trained solid waste professionals with field experience may observe a fraction of drywall in the same sample, yet their estimate of the percent of that drywall may vary, in some cases by five percent (or more if there is a lot of drywall). Human judgment is a necessary obstacle of precise visual surveying.

Fortunately, for each load surveyed, it was possible in this study to obtain a copy of the weigh ticket from the scalehouse at each host facility. Because landfill scales must be calibrated on a regular basis to assure accurate reporting of incoming waste flows, the measured weight of each load from the scalehouse are highly defensible data points.

The first exercise to tabulating the results was therefore to convert volumetric estimates for each sample into weigh-based estimates. Doing so required the following process:

1. Research and compile the raw density factors for all of the material categories defined for the study. Raw density factors were compiled based on available literature (primarily other C&D characterization studies and various recycled material manuals) as well as on MSW Consultants’ experience in conducting prior waste characterization studies;

2. Convert volumetric estimates to weight-based estimates by applying the raw density factors;

3. Compare the weight of the raw volume-to-weight conversion against the actual weight of each load as shown on the weigh tickets;

4. Apply targeted statistical analysis to identify the density factors that contribute to the variance between the calculated (item 2) and the actual (item 3) weights; and

3. RESULTS

3-2 Mecklenburg County C&D Composition Study

5. Develop adjusted density factors that, when applied to the volumetric estimates observed in the field, yield calculated weights that are, in the aggregate, within acceptable tolerances of the actual weights

Table 3-1 presents the density factors compiled for this analysis. The raw and adjusted density factors are shown, as well as the adjustment that was applied.

Table 3-1 C&D Material Density Factors (Lbs/Cubic Yard) – Raw and Adjusted

Material Group

Material Category Raw Adjusted Adjustment

Paper OCC/Kraft 100 100 0 Other Paper 157 157 0 Plastic PVC Pipe 50 50 0 Plastic Film 40 40 0 Vinyl Siding 50 50 0 Other Plastic 65 65 0 Glass All Glass 600 600 0 Metal Appliances 142 142 0 Other Ferrous Metals 570 570 0 HVAC Ducting 50 50 0 Other Non-Ferrous Metals 570 570 0 Green Waste Land Clearing/Limbs/Stumps 600 600 0 Other Yard Waste 225 225 0 Inerts Concrete/Block/Brick/Stone/Tile 1,500 1,275 (225) Dirt/Sand/Gravel 1,500 1,275 (225) Wood Pallets 50 lbs/pallet

150 lbs/crate 50 lbs/pallet

150 lbs/crate 0 0

Untreated Wood 364 309 (55) Oriented Strandboard (OSB) 364 309 (55) Treated/Painted/Processed

Wood 364 309 (55)

C&D Materials Drywall - Unpainted 325

276 (49)

Drywall - Painted 325 276 (49) Asphalt Roofing 1,250 1,063 (187) Insulation 100 100 0 Ceiling Tiles 75 75 0 Carpet & Carpet Backing 900 765 (135) Other Wastes Bagged MSW 200 200 0 Electronics 400 400 0 Bulky Wastes/Furniture 250 250 0 Mixed C&D/Other Unclassified 200 200 0

An interesting result of this exercise is that all of the variance between the estimated weight (calculated by applying raw density factors to the observed volumetric estimates) and the actual weight could be minimized by downwardly adjusting the density of nine of the 30

3. RESULTS


material categories. It is noteworthy that these nine categories are among the denser materials in C&D waste. This suggests that either (a) the industry literature on material density seems to overestimate the density of these material types, or (b) in the judgment of the field surveyor, the volume of these more dense materials was routinely overestimated.

While it is not possible to assert that the density adjustments that are shown in Table 3-1 assure complete accuracy of the results, MSW Consultants believes that the step of normalizing the volumetric estimates to align closely with the known weight of the samples improves the accuracy of the overall study results.

STATISTICAL MEASURES

Once each sample is converted from volume to weight and normalized (as described above), the following statistical measures are calculated to determine the overall composition of C&D waste.

Sample Mean: The sample mean, or average, composition is considered the “most likely” fraction for each material category in the aggregate C&D waste stream. The sample mean is determined by (i) summing the weight of each material in each sample; (ii) summing the total weigh of all samples, and (iii) dividing the first value by the second value to determine the percent-by-weight composition. Note that the sample mean, while a good estimate, is unlikely to be identical to the population mean value. The meaningfulness of the sample mean is enhanced by the following statistical measures.

Standard Deviation: The standard deviation measures how widely values within the data set are dispersed from the sample mean. A higher standard deviation denotes higher variation in the underlying samples for each material, while a lower standard deviation reflects lower variation among the individual samples. The standard deviation is stated in the same unit as the sample mean, which in this case is percent by weight.

Confidence Intervals: When a sample of data is obtained, it is analyzed in an attempt to determine certain values that describe the entire population of data under analysis. For example, in a poll of likely voters, the intent of the poll is to determine the percentage of all voters who support a given candidate, not simply the percentage of voters in the poll who support that candidate. The percentage of voters who support a given candidate in the poll can easily vary from sample to sample; but the percentage of all voters who support that candidate is a fixed value. In our sample of incoming loads of C&D waste, we are not primarily interested in the percentage composition of the sampled loads, but rather in trying to determine what the composition of the sampled loads tells us about the composition of all C&D waste generated in Mecklenburg County. A confidence interval is a statistical concept that attempts to indicate the likely range within which the true value lies. The confidence intervals reflect the upper and lower range within which the population mean can be expected to fall. Confidence intervals require the following "inputs":

The "level of confidence", or how sure one wants to be that the interval being constructed will actually encompass the population mean;

The sample mean, around which the confidence interval will be constructed;

3. RESULTS


The sample standard deviation, which is used as a measure of the variability of the population from which the sample was obtained; and

The number of sampling units that comprised the sample (a.k.a. sample size).

Throughout this section, confidence intervals have been calculated at a 90 percent level of confidence, meaning that we can be 90 percent sure that the population mean falls within the upper and lower confidence intervals shown. (The converse is also true: that there is a 10 percent chance that the population mean falls outside of the sample mean.) In general, as the number of samples increases, the width of the confidence intervals decreases, although the more variable the underlying waste stream composition, the less noticeable the improvement for adding incremental samples.

RESULTS

Figure 3-1 presents a graphical breakdown of the major material categories of Mecklenburg County C&D waste being disposed at local landfills. As shown in the Figure, Wood and Inert materials each comprise almost one-third of disposed C&D, with Other C&D Materials contributing another 20 percent of the overall waste.

Figure 3-1 Mecklenburg-Generated C&D Waste Disposed (annual tons)

3. RESULTS


Figure 3-2 ranks the categories of C&D waste from most to least prevalent. It is of definite interest that some of the most commonly disposed materials are highly recyclable (if they could be separated from other C&D waste). For example, the top three most prevalent materials are inerts (concrete/brick/rock), untreated wood and drywall. Clean concrete, brick and block, as well as untreated wood, can be tipped at the Foxhole Landfill for a reduced tip fee if they are source separated, and local manufacturer Union Gypsum will accept drywall for recycling. Ferrous metals and OCC are recyclable, with recycling programs in existence within the Charlotte region. Nonferrous metals are also recyclable, and certain ceiling tiles are accepted for recycling by an out-of-region company if they are source separated and aggregated into trailer-size quantities for transport. It appears that recycling opportunities within the C&D waste stream are significant.

3. RESULTS


Figure 3-2 Prevalence of C&D Waste by Material Category (annual tons)

0 10

,00

0

20

,00

0

30

,00

0

40

,00

0

50

,00

0

60

,00

0

70

,00

0

80

,00

0

90

,00

0

10

0,0

00

Electronics

Vinyl Siding

Appliances

HVAC Ducting

Ceiling Tiles

PVC Pipe

Plastic Film

Drywall - Painted

Crates

Other Plastic

Other Paper

Insulation

Bulky Wastes/ Furniture

Glass

Land Clearing / Limbs / Stumps

Other Yard Waste

Other Non-Ferrous Metals

Mixed C&D/ Other Unclassified

Bagged MSW

Pallets

OCC/Kraft

Carpet & Carpet Backing

Other Ferrous Metals

Oriented Strandboard (OSB)

Dirt/Sand/Gravel

Asphalt Roofing

Treated/ Painted/ Processed Wood

Drywall - Unpainted

Untreated Wood

Concrete/ Block/ Brick/ Stone/ Tile

Annual Tonnage

It was beyond the scope of this study to investigate the availability of markets for the wide range of recyclable materials in the C&D waste stream. It was also beyond the scope of this study to address the likely feasibility of developing a C&D material recovery facility (MRF) to serve the Mecklenburg County market. Local markets for recyclables are a requirement for

3. RESULTS


meaningful recycling, and development of a C&D MRF would be considered a longer term strategy for maximizing diversion from the C&D waste stream.

However, in the interest of better understanding the longer term potential to increase diversion of the C&D waste stream, it is informative to break down the C&D waste stream by its hypothetically recoverable components. Specifically, each of the material categories in this study have been assigned to one of the following three categories to describe the diversion potential of the material.

1) Recoverable: These materials are recyclable in their entirety and have currently existing markets in the Mecklenburg County region to the extent such materials are source separated for delivery to market.

2) Potentially Recoverable: At the current time, there is no mixed C&D waste processing capacity in the County. Many materials are technically recyclable, but only under any number of qualifying conditions: they must be available in significant quantity to be acceptable to the end market; they must be clean enough to recover; they must be further sorted into subcomponents prior to delivery to market; aggregate transportation and recycling costs must be competitive with disposal costs; and other reasons.

3) Unrecoverable: These are materials that do not appear to have near term potential for recycling or that occur in such small quantities in the C&D waste stream that it is unlikely they will ever be recycled.

Table 3-2 assigns each of the C&D materials in the study to the above categories.

Table 3-2 Recoverability of C&D Material Categories

Recoverable Corrugated Cardboard, Appliances, Other Ferrous Metals, HVAC Ducting, Other Non-ferrous Metal, Land Clearing/Limbs/Stumps, Other Yard Waste, Concrete/Block/Brick/Stone/Tile, Pallets, Drywall – Unpainted, Untreated Wood

Potentially Recoverable PVC Pipe, Vinyl Siding, Dirt/Sand/Gravel, Asphalt Roofing, Ceiling Tiles, Carpet and Carpet Backing, Electronics, Bulky Wastes/Furniture

Unrecoverable Other Paper, Film Plastic, Other Plastic, All Glass, Oriented Strandboard (OSB), Treated/Painted/Processed Wood, Drywall – Painted, Insulation, Mixed MSW, Mixed C&D/Other Unclassified

Figure 3-3 shows the resulting breakdown between recoverable, potentially recoverable, and unrecoverable materials in C&D waste.

3. RESULTS


Figure 3-3. Prevalence of Hypothetically Recyclable Materials in Aggregate Disposed C&D Waste (Percent by Weight)

As shown in Figure 3-3, this study found that 62 percent of the C&D waste stream is made up of materials that are recoverable within the existing end markets in Mecklenburg County to the extent they can be source separated. At the current time, this represents the maximum potential diversion that could be achieved from the C&D waste stream. Realistically, this level of diversion will not be approached in the absence of establishing a mixed C&D processing capability, because many of these recoverable materials cannot be economically source separated at construction sites.

It should also be noted that mixed C&D processing facilities in other areas of the country have demonstrated that there are significant limitations to achieving high capture rates even with a customized sorting system. While it was beyond the scope of this project to report on the range of C&D processing technologies and diversion potential at C&D processing facilities, anecdotal evidence from several facilities in the Northeast and South Florida indicate that sorting technology limitations, including pre-process size reduction that is necessary to feed C&D debris through a conveyor sorting system, render many recyclable items too difficult to recover, thereby reducing recycling rates. When viewing Figure 3-3, it is therefore important to consider the 62 percent of “recoverable” C&D as being an academic portrayal of the materials contained in C&D debris. The maximum recycling rate in the C&D waste stream will likely be significantly lower, even in the face of aggressive diversion strategies such as mixed C&D processing.

Of the remaining material in the C&D waste stream, it may be possible to target another 19 percent of the C&D waste stream for diversion through a combination of development of end markets and improvements in collection and processing. Further, the study found that 19 percent of disposed C&D waste is comprised of materials for which legitimate recycling, composting or reuse processes or opportunities have not yet been developed (or if they have, they are not widely in practice for material found in the C&D waste stream). Over time, it is possible that there would be opportunities to increase recycling of new materials that are currently being disposed, but achieving diversion of the “unrecoverable” materials is unlikely to be significant even after significant improvements to the C&D recycling infrastructure.

3. RESULTS


The detailed composition of C&D waste in Mecklenburg County, including the sample mean, standard deviation, and 90 percent confidence intervals, is contained in Table 3-3. In addition to showing the percent composition statistics, this table also applies the results to the 377,120 total tons of C&D waste that were reported to have been generated in Mecklenburg County in 2007 and disposed in landfills.

3. RESULTS


Table 3-3 Mecklenburg County Detailed C&D Waste Composition

90% Conf. Interval


Annual Quantity

(tons)


Paper Subtotal 4.5% 0.5% 3.7% 5.3% 17,119 PVC Pipe 0.1% 0.0% 0.1% 0.2% 457 Plastic Film 0.3% 0.1% 0.2% 0.4% 1,283 Vinyl Siding 0.1% 0.0% 0.0% 0.1% 194 Other Plastic 0.6% 0.1% 0.5% 0.7% 2,191






Wood Subtotal 31.8% 2.2% 28.2% 35.4% 119,865 Drywall - Unpainted 6.8% 1.1% 5.0% 8.7% 25,806 Drywall - Painted 0.4% 0.2% 0.1% 0.7% 1,613 Asphalt Roofing 6.4% 1.2% 4.4% 8.4% 24,084 Insulation 0.8% 0.2% 0.5% 1.0% 2,888 Ceiling Tiles 0.1% 0.0% 0.0% 0.1% 292 Carpet & Carpet Backing 5.3% 1.0% 3.7% 7.0% 20,167



TOTAL 100.0% 377,120

3. RESULTS


Table 3-3 applies the results of this study to the total quantity of C&D reported by C&D landfills to have originated in Mecklenburg County. Tables 3-4 and 3-5 provide the composition of C&D debris at the Foxhole Landfill and the North Mecklenburg Landfill individually. Although it was not intended to analyze the results separately by facility, a cursory review suggests that the C&D waste stream entering each facility is comparable in its composition.

3. RESULTS


Table 3-4 Foxhole Landfill C&D Waste Composition

90% Conf. Interval


Annual Quantity

(tons)


Paper Subtotal 5.0% 0.7% 3.8% 6.3% 8,130 PVC Pipe 0.1% 0.0% 0.1% 0.1% 145 Plastic Film 0.4% 0.1% 0.2% 0.5% 619 Vinyl Siding 0.1% 0.0% 0.0% 0.1% 87 Other Plastic 0.6% 0.1% 0.4% 0.7% 953





Inerts Subtotal 30.3% 5.1% 21.8% 38.7% 48,727 Pallets 1.6% 0.2% 1.3% 2.0% 2,653 Crates 0.1% 0.1% 0.0% 0.2% 146 Untreated Wood 17.3% 2.2% 13.7% 20.8% 27,803 Oriented Strandboard (OSB) 7.1% 1.2% 5.1% 9.1% 11,402 Treated/ Painted/ Processed Wood 6.0% 0.9% 4.6% 7.4% 9,674

Wood Subtotal 32.1% 3.3% 26.7% 37.5% 51,678 Drywall - Unpainted 5.7% 1.5% 3.2% 8.1% 9,154 Drywall - Painted 0.4% 0.2% 0.1% 0.7% 597 Asphalt Roofing 6.8% 1.8% 3.9% 9.8% 10,993 Insulation 0.7% 0.2% 0.4% 1.0% 1,153 Ceiling Tiles 0.1% 0.0% 0.0% 0.1% 110 Carpet & Carpet Backing 4.2% 1.2% 2.2% 6.1% 6,719



TOTAL 100.0% 161,047

3. RESULTS


Table 3-5 North Mecklenburg Landfill C&D Waste Composition

90% Conf. Interval


Annual Quantity

(tons)

OCC/Kraft 3.2% 0.5% 2.4% 4.1% 4,183 Other Paper 0.7% 0.2% 0.4% 1.0% 931

Paper Subtotal 4.0% 0.6% 2.9% 5.0% 5,115 PVC Pipe 0.2% 0.0% 0.1% 0.2% 203 Plastic Film 0.3% 0.1% 0.2% 0.4% 374 Vinyl Siding 0.0% 0.0% 0.0% 0.1% 63 Other Plastic 0.6% 0.1% 0.4% 0.7% 735






Wood Subtotal 31.4% 2.9% 26.7% 36.2% 40,619 Drywall - Unpainted 8.2% 1.7% 5.3% 11.0% 10,553 Drywall - Painted 0.5% 0.3% 0.0% 1.0% 637 Asphalt Roofing 5.9% 1.6% 3.3% 8.5% 7,603 Insulation 0.8% 0.3% 0.4% 1.3% 1,063 Ceiling Tiles 0.1% 0.1% 0.0% 0.2% 114 Carpet & Carpet Backing 6.7% 1.7% 3.9% 9.5% 8,645



TOTAL 100.0% 129,209

3. RESULTS




APPENDIX G

Builder Focus Group Notes

FOCUS GROUP Barriers to Recycling Construction and Demolition Waste Materials

in Mecklenburg County

Agenda and Questions used with Residential and Commercial Builders

Agenda

I. Welcome/Introductions (10 minutes) o Why are we having the focus group? Brief explanation of research study. o Introduce DSM Environmental (facilitator and note taker) and our background in

recycling and solid waste management. o Confidential nature of comments made. o Participant introductions:

• First name only and position in company • Length of time with company • Personally responsible for contracting for waste and recyclables removal? • Size of company – large, medium, small • Company specialty, LEED involvement, new construction, renovations, demolition • Location of majority of work – city, suburbs,

II. Objective of Meeting (2-5 minutes)

• Major objectives of focus group meeting - To learn status of C&D recycling among contractors. For example, what are the barriers to recycling and the opportunities for recycling construction wood and other materials by commercial and residential contractors? How do they differ among builders and demolition firms? The goal is to gain input into County programs and the landfill ban decision.

• Detail on research project; • Use of the focus group information collected; and, • Stress that goal is to obtain as many diverse thoughts as possible.

III. Ground Rules of Meeting (2 minutes)

• We are not here to judge your ideas but to try to understand the issues • One person talk at a time, limit one person dominating meeting • Stick to the questions that are asked – get closure

IV. Focus Group Questions (45 minutes) (See following pages)

V. Closing (2 minutes)

Reiterate use and value of information, thank participants and if appropriate, don’t forget

to use this opportunity to ask for involvement in your programs. If it has become clear during the focus group meeting that there are a number of questions about recycling or other County programs, time can be set aside after the formal end of the focus group to address these questions.

Focus Group Questions 1) What materials do you typically recycle?

• Clean Wood • Pallets • Gypsum • Metals • OCC • Asphalt Shingles • Other

2) What motivates you to recycle on the job site?

• LEED • County Recycling Policies • Cost • Green image • Clients want it?

3) What are the barriers to recycling?

• Haulers offering separate containers? • End uses? Market specifications? • Space on site? • Cost • Training employees • Other?

4) What do you think keeps other construction companies from recycling in Mecklenburg County? 5) How helpful are the haulers/waste management companies in enabling your company to recycle? 6) Where does your non-recycled waste go – C&D landfill or MSW landfill?

• If your waste goes to a C&D landfill, do you ever get notified that your load has been rejected because there is too much waste in it?

• Do you haul yourself, or do you contract for collection and disposal? • If you contract, do they supply separate containers for waste and for recycling? • Do they charge you extra for the recycling containers? • If your waste goes to an MSW landfill, what would the impact be of a ban on the disposal

of clean wood and pallets? 7) Would you put materials in a separate container if there was room? 8) Does your recycler require you to keep the clean wood separate from OSB or painted/stained? 9) What do you think the County could do to make it easier to recycle?

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FOCUS GROUP NOTES

COMMERCIAL BUILDERS MECKLENBURG COUNTY

DECEMBER 11, 2007

Participants: (1) Assistant Project Manager, Responsible for LEED paperwork and managing waste and recyclables. Small to medium sized firm specializing in demolition (2) Same company. Project Manager, been with the company for 25 years (3) Project Manager/Vice President. Large general contractor, one-half new construction, one-half renovation (primarily interior). Responsible for waste management for some jobs, but not all. (4) LEED certification specialist, large general contractor. New construction and renovation (5) LEED specialist – same company, new to company (6) Project Manager, large general contractor, has responsibility for LEED certification on projects that require LEED certification. (7) Project Manager, medium to large general contractor Question: What percent of projects that your company has done (over the last year or so) require recycling? (2) 40% require recycling (3) 25% require recycling (4) 35% - 40% require recycling (6) 10% require recycling (7) 10% - 15% require recycling Question: What materials do you typically recycle? (1) Metal, untreated/unpainted wood, concrete and asphalt

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(2) Carpet, ceiling tile, lights, some glass, OCC (on LEED projects primarily, otherwise not common), sheetrock (if we can fill a roll-off container). We don’t do asphalt shingles, vinyl siding or any plastics. (3) If there is sufficient room on site for (recycling) containers we will do metal, drywall and clean wood. We always recycle carpet from interior renovations, and we will salvage lights, if it is possible. We try to send OCC back with the vendors. (3) and (6) Furniture vendors will take back the OCC. (4) We will bring in a grinder and grind sheetrock for disposal on-site in South Carolina. It is not yet allowed in North Carolina. For LEED projects, we will typically hire a sub-contractor to place roll-offs (on the site) which we can fill with commingled materials which the sub-contractor will separate and recycle off-site for us. (6) On non-LEED projects we will typically only recycle metal. For LEED projects we will recycle sheetrock, metal, concrete, plastic (bottles and shrink wrap only), and OCC. Clean wood can be a problem because it requires a separate dumpster on-site. (7) We mulch land clearing debris. We recycle concrete and metal. Typically the companies delivering material on pallets will take the pallets back with them. (2) We usually salvage pallets for our own use. (3) Pallets are a problem for us on small jobs. Question: What motivates you (your company) to recycle? (6) Money! Metal is worth recycling and concrete is costly to dispose of. On LEED projects we recycle because we are required to. (3) Sometimes we recycle because it is the right thing to do. Carpet and ceiling tiles are easy and don’t cost much to recycle. A number of our clients will pay a little extra to have us recycle. (2) We get good publicity out of recycling, and have gotten some additional projects out of it, so there is some marketing value. We have had good markets for carpet and ceiling tiles. (7) The owner of company has a tendency to not be wasteful, so we try to recycle even if it is not a LEED project. Sometimes recycling can be good marketing, but cost is important (to us).

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Question: How important are the costs of recycling (to your company)? (4) Important enough to pay attention to the extra cost of recycling, but some customers like the PR (from recycling). (3) We will show the additional cost of diversion on our (job) estimate. If recycling shows less than an increase of 1 or 2 percent, customers will generally agree to it. (6) We don’t typically cost our waste management on non-LEED projects. (So customers don’t even have the choice of recycling unless they bring it up.) (3) We are much more likely to recycle if we have the space for additional dumpsters. (3) and (4) It is cheaper to pay someone else to deal with all of the logistics and tracking of recycling, than to do it yourself, especially for LEED certification projects. (4) More customers have knowledge that landfills are filling up so they want recycling, but it isn’t worth it to ship recyclables very far. Question: What are the barriers to recycling? (4) The location of the job in relation to the markets for the recyclables. (6) Finding a market for the material and someone willing to take the material. (7) (Both) Cost and Time (as they equal) Money. (3) Markets – While gypsum is critical on a LEED project because of weight, it isn’t worth it to transport it very far as it is still cheaper to landfill it than to recycle. (4) Why recycle when landfills are so cheap? (3) and (4) Space can be a real factor (barrier). Question: How many of you hire someone to separate and recycle off-site? (6) I hire a low cost young person on-site to separate materials for recycling. I force sub-contractors to recycle, but we handle the trash for our sub-contractors. (4) We no longer allow our subs to throw lunch trash in our dumpsters. We handle all trash but force subs to meet recycling requirements. (7) Most projects that we do have enough room to have multiple cans for recycling. Sometimes it is cheaper to have multiple cans than a single can.

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(2) Building codes have changed making it difficult to salvage materials since they don’t meet new building codes. For example, some older doors don’t have fire rated label even though they are the same as the new doors. (This makes it impossible to salvage this material.) (4) Construction waste management is one of the most frustrating parts of my job on LEED projects. It requires constant supervision and education. (3) LEED certification paperwork takes more time than the entire time required to bid a project. (6) I hire a company to do the LEED documentation. (3) If I don’t have space to put in multiple cans to keep everything separate, I end up having to weigh everything separately which is a huge cost and huge amount of paperwork. (Required of the LEED documentation.) (2) Even if it is not a LEED project, we still have sorting issues (for recycling). (4) Recycling is still fairly new in the County, so even if not a LEED project, we can’t trust them to verify (that the material has been) recycled. Question: Do you know where your waste and recyclables go? (6) We have to document for LEED projects. Drywall and plastics are a huge problem in the County. (7) (We think that) 90% of material goes to private facilities (2) BFI or North Mecklenburg landfill are the only places for disposal on the north side of County. (6) I don’t know where it goes, wherever CWS takes their stuff. (2) Don’t go to Foxhole (4) Don’t go to Foxhole, too expensive (2) Lake Norman Question: Have you had material rejected? (6) Notified that stuff sent to the plastic recycler went to the landfill.

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(2) Yes with wood. Can’t put wood into an inert debris landfill; only (can put) concrete, brick, block and dirt, etc. in an inert debris landfill. (1) Won’t take cable, even at the metal recycler. (4) I had a load of wood with two soda bottles rejected, so will get a third party like WM to take it because they own the landfill or have a relationship with the landfill. Question: What keeps other companies from recycling? (2) They don’t have the knowledge of markets and what is recyclable. (3) Some neighborhoods don’t even have household recycling (so they wouldn’t consider recycling). (4) Cost. (6) Cost. (4) They don’t know about markets for carpet and ceiling tiles. (3) You have to know people (e.g. locations to take the material) to recycle drywall (3) Everyone knows that metal is recyclable, but people don’t know gypsum is recyclable. Question: What are end uses for wood? (2) Most goes to mulch. (4) I don’t know. (1) Clean wood costs $16 per ton to get rid of. (3) Most is chipped. (2) We have sent some for boiler fuel (6) and (7) Wood goes to Foxhole Question: What percent of gypsum are you able to recycle? (6) Only on LEED projects (do we recycle gypsum).

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(3) They only take non-painted so around one-half, but then only if you have a separate dumpster. (6) I require my subcontractors to sort it out, or I charge them for disposal. (4) If it is a public job I don’t get to choose my subcontractors. (6) It is more the market for gypsum (than the subcontractors). (3) Space is also a factor (to the ability to recycle gypsum). (4) On-site contamination is a huge barrier (to recycling gypsum). (3) There is lots of illegal dumping in roll-offs, I always pull all (containers) before Christmas otherwise they are all full (of household trash) after Christmas. (2) We often have to fence dumpsters to protect against illegal dumping, but in downtown even fencing isn’t enough. (3) Training subcontractors is a continual job of education and enforcement. (6) Just getting subcontractors to use dumpster is hard enough.

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FOCUS GROUP NOTES

RESIDENTIAL BUILDERS MECKLENBURG COUNTY

DECEMBER 13, 2007

Facilitated by:

DSM Environmental Services, Inc.

Agenda and Introductions (See outline): Participants: (1) Purchasing Department, Medium to Large residential development company. Been with the company for 15 years (2) Project Manager, Small infill custom home builder and remodeler, 25 to 50% of projects are certified green buildings (3) President, Small contractor, do all business in downtown area, mostly renovations, 30% of our work will be green buildings (4) Purchasing Manager, medium to large residential developer working in South and North Carolina. Have national vendor handling our solid waste (5) Assistant Production Manager, medium sized company, high end homes. Have only been with the company one year, but am involved in all contracts (6) Expediter, same company as (5), deal with waste management on-site (7) General Contractor, Small company (3 employees), build custom homes Question: What materials do you typically recycle? (5) Don’t recycle now, but I am here to learn about how I might in the future. I am interested in recycling. (4) We recycle concrete on a limited basis. (6) We try to reuse stuff (e.g. building materials). We take some (materials) to the Habitat Restore.

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(3) We recycled metals - we have an informal arrangement with local garages. We also recycle concrete and brick – we bring it to a place on Route 16 that grinds it for reuse under slabs. We also recycle some shingles. We don’t recycle wood or gypsum but would love to find a place to take gypsum. (2) We do some similar things to (3). We do a lot of salvage. We take timbers and turn them into flooring. We do a lot of OCC recycling – I drive it downtown myself to recycle it. We are looking into grinding gypsum to use as a “dust path”. We also put out a curbside recycling bin for employees to recycle their pop bottles. We try to use scrap wood as much as possible. We are more successful with ordering less wood and forcing carpenters to use more of what they have (rather than recycling wood). (1) We recycle carpet (or have recycled carpet). We did recently do a knock down and we contracted with a demolition firm to do the recycling. Question: What motivates you to recycle? (7) In Florida, where we used to be located it was economical to recycle because of higher landfill fees, and because it was easy to find people to help you recycle. That was the motivation there, but not here. Cost is a barrier. (4) Usually we are not very motivated to recycle. Our work is all about cycle times, we make money if we can complete a home in 50 days or less. Recycling just adds time to our projects and (time adds) money. Usually, we are motivated by regulations. It would also be great if we could find a third party to take the material and recycle it. Our main focus is to get it off the job site as quickly as possible. However, if there were enough demand for “green buildings,” that would be an incentive. (3) Homeowner driven. I will give the homeowner a cost for throwing it away and one for recycling of certain materials. If homeowner wants to pay the extra cost for recycling I will do it, otherwise I won’t. (5) A lot of our jobs are cost plus, so we charge for collection and disposal. We are getting increased interest from our customers for (addressing) environmental issues, so we will recycle if they want to pay for it (and it is important to them). We want to take a leading approach on environmental issues so we are concerned and interested about positive environmental impact. It is the right thing to do. If the County just made everyone do it, it would be great. (2) It levels the playing field if everyone was required to do it (recycle). (1) We are production driven so are always looking to increase efficiency. If we can create less waste, we increase efficiency, so we are very organized in our building construction, but not in our waste management

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(4) If there were locations throughout the County for recycling of waste material it would help us to recycle. (2) We are willing to do it even though it is not very cost effective now, so when markets for recyclables get better we think we will be ahead of the game. (4) That is the reason I came to the meeting (to learn more about how to recycle, how we can get involved). Question: What are major barriers to increasing recycling? (7) Information – I don’t know what is available (to help us recycle). Where does the material go, and what does County have for facilities (recycling drop-offs)? It would be great to have a single source for all recycling information. I do have the County list, but that requires me to deal with a whole list of companies, while I would like a single source/phone number for recycling (all materials). (3) We need a third party who can handle all our recycling. We can’t handle the logistics of organizing recycling. (2) I don’t think it is that much more expensive to recycle, but it is hard to find a third party to separate the material for recycling. (5) Recycling is just one more thing for our field supervisors to have to keep track of. It won’t be a priority for them if it is a hassle for them. (4) A supervisor with 25 to 30 houses going all at once is not going to give priority to recycling if it takes any additional time. (1) And there is no incentive for the superintendent – if it costs him more time it just makes it worse for him. (2) Documentation (of recycling activity) just adds time and expense. Question: How helpful is the waste management industry (e.g. waste haulers)? (6) Same people who do our Porta Potties do our waste removal. It is easy to just put a dumpster next to the Porta Potty. (2) The waste companies see it coming but are really just starting to engage (in the idea of recycling). Question: Do you know where your waste goes?

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(4) North, north Meck, South, Foxhole (3) Concrete and brick to Tommy Bryce, other waste goes towards Huntsville (2) Never traced it (don’t know) (7) Don’t know what landfill it goes to (5) Wherever Five Points Waste takes it (4) We have a national contract with one company who comes every day to collect our waste, but there is no recycling. Question: Would you put materials in a separate container if there was room? (2) OCC would be first thing (we would separate), but the biggest thing is that there is so much illegal disposal in the boxes at the construction site (makes it hard to have a clean box of material for recycling). (3) The homeowners themselves (that we are working for) throw their stuff in the dumpsters. (2) We now have a clause in our contract prohibiting homeowner trash in our dumpsters. (7) Wood and drywall would be first materials (we would separate). (1) It would definitely be the heaviest materials (that we would recycle on the jobsite) first. (2) Drywall might be the easiest because it comes all at one time, while OCC waste is generated throughout the job (making it harder to recycle). (3) If we are doing a major demolition job we would probably have three dumpsters – one for concrete and brick, a second for gypsum and plaster, and a third - the rest of trash. The construction phase is different because everything is spread out, and there isn’t as much space as with a demo job. (5) If the separate dumpsters are left over the weekend they will be filled with household trash. Question: What if we banned clean wood from disposal? (5) What do you mean by clean wood. Most wood could have nails in it? How about painted wood?

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(4) You better have alternative locations for the material (as there are not enough locations you can take it now). (2) Is there any way to sort it out from the rest of the wood? What about MDF, OSB? (4) What about finger jointed pine? (3) (I think that) some new companies would spring up to collect it. (4) It is all about the cycle time, all competing for shortest cycle time. (5) Time is money; we would need a third party to manage the wood. (3) At least with a ban there would be a level playing field. Question: Do you ever recycle plastic film? (6) We try to reuse what ever we can, but never recycle it. (2) Same. Question: What about gypsum? (2) You cannot grind it and land apply it in NC (so what would you do with it). (4) Our subcontractors are required to take it back with them or make arrangements for disposal. (7) Our subcontractors would have to deal with it. Question: How much are waste management costs compared to all other costs? (7) They add up. (6) The big dumpsters are $600 per pull, but it doesn’t amount to much compared to all the other costs. (2) Not much (compared to other costs). (4) In publicly traded production world trash, they equal about 1% of job costs. We (have in our) contract(s) that the OCC and drywall are the subcontractors’ responsibility. All other trash costs are ours

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(2) We don’t separately account for it, just part of our overhead. (3) Our subcontractors take the drywall and roofing, and the framing and OCC go in the dumpster. Question: What would it take to recycle more? (4) It has to be required or my competitors will have lower costs. (3) Key (to recycling) is requiring it for all. (That is) we must have a level playing field.

final report december 2008 -...

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