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### Resinated Wood, Scrap Tire, and Pulp/Paper Sludge Support Document for the 2011 Proposed Rulemaking;
Identification of Non-hazardous Seconda ry Materials That Are Solid Waste EPA Docket ID: EPA-HQ-RCRA-2008-0329 / Phase: Proposed Rule (2011)

November 22, 2011



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This document was developed in support of th e 2011 proposed rulemaking, “Identification of Non-Hazardous Secondary Mate rials That Are Solid Waste” (2011 NHSM Proposed Rule). Specifically, this document provides informati on regarding the contaminant levels, heating values, and management practices for the non-ha zardous secondary materials (NHSMs) that are discussed in the 2011 NHSM Proposed Rule for: (1 ) resinated wood; (2) sc rap tires; and (3) pulp and paper sludge. These NHSMs were assessed base d on all information available to the Agency at the time of the proposed rulemaking.Page 2 of 10 

### 1. Resinated Wood

Resinated wood are wood products (containing resin a dhesives) derived from primary and secondary wood products manufacturing and comprise d of such items as board trim, sander dust, and panel trim. These secondary materials may be used to manufacture composites or used as fuel. Resinated wood residuals are primarily generated from the manufacturing of wood products, such as medium density fiberboard (M DF), particleboard, plywood, and oriented strand board (OSB).

Resinated wood is highly valued within the wood products industry fo r its high fuel value relative to other wood fuels gene rated and burned at these facil ities for energy recovery. Many facilities rely on mixing of thes e low moisture content wood ma terials with higher moisture
materials. Resinated wood residua ls are routinely transferred be tween either intra- or intercompany facilities and used as either “furnish” (i.e., raw materi als) or fuel at the receiving facilities. The material being transferred off-s ite is used and handled in the same manner that
resinated wood residuals are used an d handled when generated on-site.

A. Contaminants

The composition of resinated wood residuals can va ry widely depending on the type of wood and the adhesives used. In general, engineered wo od is comprised of at least 90 percent wood, and often contains formaldehyde, a common resin. Ta ble 1 contains sample composition information for an engineered wood trim product. Table 2 cont ains data on other contaminants contained in resinated wood compared to coal and wood.

Table 1: Common Composition of Engineered Wood Trim 1

Material Percentage (%)

Wood 90 – 91

Resin 5 – 6

Wax 2 – 3% 2 – 3 Top Spray (Melamine) <1 Laminating Adhesive <0.5

Total 100



### An alternative source indicates that resina ted wood typically contains between 92 and 100 percent wood, and 0 to 8 percent formaldehyde. 2

1 Collins Wood. “Material Safety Da ta Sheet: Wood Dust,” 2005, Accessed on April 15, 2009 at: http://www.collinswood.com/WoodProduct s/Resources/MSDS_TruWood_Trim.pdf.

2 Universal Forest Products, Inc. “Mat erial Safety Data Sheet: Wood Dust,” 2005. Accessed on April 15, 2009 at: http://www.ufpi.com/litera ture/wooddust-165.pdf.Page 3 of 10 

### Table 2: Contaminants in Resinate d Wood Compared to Coal and Wood

CONTAMINANT CONCENTRATIONS (in Parts Per Million by Weight)

Range of Resinated Wood Values 1 Range of Traditional Fuel Values for
Solid Fuels (EPA data unless otherwise noted) 3

Contaminant
Concentrations
for Sander Dust
with Resin 2 Contaminant
Concentrations for
Panel Trim 2 Coal Wood/Clean
Cellulosic Biomass

Arsenic < 0.3 - < 1.3 < 1.1 ND – 174 ND – 298

Beryllium < 0.01 - < 0.50 < 0.01 ND – 206 ND – 10

Cadmium 0.03 - 0.09 0.1 ND – 19 ND – 17

Chlorine 20 -2,600 - ND – 9,080 ND – 5,400

Fluorine - - ND – 178 ND – 300 5

Mercury < 0.002 - 0.004 0.002 ND – 3.1 ND – 1.1

Nitrogen - - 13,600 – 54,000 200 – 39,500 4

Selenium < 0.3 - < 1.3 < 1.1 ND – 74.3 ND – 9.0

Sulfur - - 740 – 61,300 ND – 8,700 4

Chromium 0.19 - 0.40 0.09 ND – 168 ND – 340

Lead 0.20 - 0.50 < 0.2 ND – 148 ND – 340 4

Manganese 18.10 - 160.0 113 ND – 512 ND – 15,800

Nickel 0.15- 0.50 0.09 ND – 730 ND – 540 4

Sources and Notes: 1. Data provided by AFPA in background paper entitled, “Identification of Non-Hazardous Secondary Materials That are Solid Waste; Fina l Rule (40 CFR Part 241), Implications For Forest Product Industry Fuels.” June 8, 2011. This document has been placed in Dock et ID No. EPA-HQ -RCRA-2008 -0329. 2. Data for sander dust with resin based on six samples. Data for panel trim based on one sample. EPA does not have formaldehyde information specific for either material. 3. USEPA, Office of Air Quality Planning and Standards (OAQPS), Boiler 2011 Database and CISWI 2011 Database, available at http://www.epa.gov/ttn/atw/boiler/boilerpg.html#TECH and http://www.epa.gov/ttn/atw/1 29/ciwi/ciwipg.html#TECH respectively. 4. Energy Research Centre for the Netherlands, Phyllis Biomass database. http://www.ecn.nl/phyllis
NOTE: non-detect values are listed as ND



### EPA has acknowledged a general lack of data rega rding the levels of formaldehyde in resinated wood. In the 2011 NHSM Final Rule, the Agency found that formaldehyde levels in resinated wood would be less than 200 ppm, based on the na tionwide implementation of the California Air Resource Board (CARB) Composite Wood Airborne Toxic Control Measure, per Public Law 111-199 (which establishes consiste nt standards for wood products across the country). Since the rule’s promulgation, industry has provide d additional data suggesting that the CARB standards will have a greater impact on reduc ing formaldehyde levels than previously understood, making it highly unlikely that formalde hyde levels will be present above 100 ppm in
resinated wood that is currently generated. 3

3 American Forest and Paper Association data discussed in a June 13, 2010 meeting with EPA. EPA Docket ID EPA-HQ-RCRA-2008-0329.Page 4 of 10 

### EPA has also acknowledged a general lack of da ta regarding the levels of formaldehyde in traditional fuels—both in natural wood, as well as coal. For example, in the 2011 NHSM Final Rule, the Agency noted limited data that found natural wood as having 0.6 and 8.5 ppm of formaldehyde. Since the final rule’s promul gation, industry has provi ded additional data indicating that formaldehyde le vels in natural wood can be as high as 27 ppm.

B. Meaningful Heating Value

Data from EPA suggests that the thermal value of resinated wood dust varies from 4,500 to 8,000 Btu per pound. In general, higher moisture content results in a lower thermal value. 4 

### In addition, EPA received comments on the 2010 NHSM proposal re garding the heating value of resinated
wood. These comments indicated that resinated wood re siduals have about 5 percent moisture content, with heating values typically between 8, 500 – 9,000 Btu/lb (as fired). This fuel value is equal to or better than unadulterated wood, which has higher moisture content. 5



### C. Managed as a Valuable Commodity

As discussed in the 2011 NHSM Final Rule, EPA received informa tion from commenters regarding how resinated wood is managed as a va luable commodity when it is used as a fuel. 6



### These comments indicated that resinated wood re siduals are typically pn eumatically transferred through ducts, stored temporarily in a fuel silo, and then utilized in boilers to provide heat to hot presses and dryers.

In fact, wood product plants have been designed to specifically utilize th ese residuals that the wood manufacturing process creates and would not be able to operate as designed without this material. For example, sander dust injector sy stems have been specifically developed to accommodate the unique combustion requirements of this material and these injector systems have been installed on many boiler and wood drying systems within the industry. 7 

### Burners designed to combust sander dust or trim may not be suitable for combusting other fuels—thus, the costs associated with switching to anot her type of fuel w ould be significant. 8 

### Overall, in composite panel manufacturing, plants typically re use 58 percent of these residual materials in the process and 35 percent is burned for energy recovery. 9

4 United States Environmental Protection Agency. “AP 42, Fifth Edition: Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources,” 1995. Accessed on April 14, 2009 at: http://www.epa.gov/ttnchie1/ap42/ch01/final/c01s06.pdf.

5 See 76 FR 15500-15501.

6 Id.

7 American Forest and Paper Association, August 3, 2010. EPA Docket ID EPA-HQ-RCRA-2008-0329.

8 For example, Composite Panel Association, in comments on the NHSM Proposed Rule, stat ed, “Estimates for the cost of a composite panel plant to switch boiler fuel from a trim/sander dust mix to natural gas ranged from $1 million to $3.5 million a year depending on boiler size and the price of natural gas. For direct fired dryers alone, the cost to switch from sander dust to natural gas ranged from $350,000 to $1.4 million a year, again depending on dryer size and gas prices. These costs do not include the re-engineering costs that would be necessitated nor do they include the cost of transportation or of f-site disposal of this valuable fuel. Moreover, these costs do not take into account the severe costs implications on all wood product facilities th at currently utilize resinated fuels in process heaters or dryers.” EPA Docket ID: EPA-HQ-RCRA-2008-0329-1358.

9 The Generation and Utilization of Residuals from Compos ite Panel Products; Forest Products Journal 54:2, 2004;
David C. Smith.Page 5 of 10 

### 2. Scrap Tires

A major use of scrap tires is as fuel, either in wh ole form or as tire-derived fuel (TDF) chips. Whole tires are frequently used as fuel in cement kilns, and the reinforcing steel within the tires provides an additional benefit because the steel wire is incorporated in the clinker used to make cement product. 10 

### Otherwise, the use of whole tires is limited by whether they are compatible
with the combustion and hand ling characteristics of i ndividual combustion units. 11,12 

### The use of whole scrap tires or TDF in combustion units is typically limited to blends of less than 30 percent of total energy in put due to the high rates of heat rele ase and the low moisture content of the scrap tire material. The proposed rulemaking addresses specifically sc rap tires that are not discarded and are managed under the oversight of established tire collectio n programs, including
tires removed from vehicles and off-specification tires.

A. Contaminants

Table 3 summarizes the contaminants in scrap tires 13 

### and solid traditional fuels. 14

10 Gray, Terry. 2009, TAG Resource Recovery. Personal Communication. August 24, 2009.

11 Id.

12 United States Environmental Protectio n Agency (EPA). 2008c, “Tire Deri ved Fuel,” accessed August 20, 2008

at: http://www.epa.gov/epaoswer/non-hw/muncpl/tires/tdf.htm

. 13 Calcium iron and zinc are elemental constituents reported in TDF, but are not considered to be “contaminants” per the §241.2 definition so they are not included in the tabl e. The scrap tires are usually reduced to small chips (like tire-derived fuel chips) in order to perform the chemical analysis.

14 There are additional contaminants in coal as defined in §241 .2 that are not listed in this table since only the values for coal are given when there are values represented for scrap tires comparison.Page 6 of 10 

### Table 3: Contaminants in Scrap Tires and Traditional Fuels

CONTAMINANT CONCENTRATIONS (in Parts Per Million by Weight)

Contaminants Range of TDF Values Range of Traditional Fuel
Values for Solid Fuels 4

ASTM Data 1

referenced in
the 2011 NHSM
Final Rule AF&PA Data Coal and
Wood / Clean Cellulosic
Biomass 5 Range 2 Mean (standard deviation) 3

Arsenic - 0.23 – 18 2.970 (4.584) ND – 298

Beryllium - ND – 0.39 0.127 (0.112) ND – 206

Cadmium 6 0.15 – 2.2 0.919 (0.431) ND – 19

Chlorine 1,490 40 – 630 236 (127) ND – 5,400

Fluorine 10 - - ND – 300 6

Mercury - 0.001 – 0.026 0.008 (0.006) ND – 3.1

Nitrogen 2,700 - - 200 – 54,000

Selenium - ND – 8.97 1.519 (1.958) ND – 74.3

Sulfur 19,200 - - ND – 61,300

ELEMENTS IN METAL STEEL FROM TIRE BELTS; NOT EXPECTED TO BE

RELEASED TO EMISSIONS IN A CONVENTIONAL BOILER 7

Chromium 97 1.8 – 210 27.85 (37.73) ND – 340

Lead 65 2.4 – 250 63.53 (52.99) ND – 340 6

Manganese <100 9.1 – 1,800 430 (516) ND – 15,800

Nickel - 1.7 – 120 17.82 (22.26) ND – 730

Sources &Notes: 1. See 76 FR 15456, the ASTM data was supplemented by additional commenter data. 2. The range of values was compiled from two sets of supplemental information sent by AF&PA. The data overview was discussed in a meeting with AF&PA and EPA on 6/13/11. The data are located in the docket for the 2011 Proposed Rule (EPA Docket ID EPA-HQ-RCRA-2008-0329). 3. The mean and standard deviation is provided from the data in the supplemental information titled “NHSM Fuel Contaminant Analysis Mill Assessment 4- 11” from AF&PA (in same docket as #2 above). 4. USEPA, OAQPS data for coal and wood unless otherwise noted. Boiler 2011 Database and CISWI 2011 Database, available at http://www.epa.gov/ttn/atw/boiler/boilerpg.html#TECH and http://www.epa.gov/ttn/atw/1 29/ciwi/ciwipg.html#TECH respectively 5. A comparison to solid fuels is applicable when the unit is designed to burn solid fuels, typically coal and wood/clean biomass. In the Major Source Boiler rule (76 FR 15608), EPA established emission
standards for fuel-based HAP for th e solid fuels subcategory, which in cludes units that combust coal and/or biomass, as well as other non-waste solid materials. The discussion of comments in that rule at 76 FR 15635 highlights the wide variety of fuel inputs, and that some boilers are designed to burn varying combinations of fuels and fuel qua lities. Such boilers are not able to reach full load on any single fuel, and must adapt to process stream and load demands. This supporting document assumes that units that burn scrap tires can also burn wood or coal. 6. Energy Research Centre for the Netherlands, Phyllis Biomass database. http://www.ecn.nl/phyllis

. 7. The concentration of metals in the steel wire is 98.5 percent iron (not a HAP),and chromium, lead, manganese, lead, and nickel (which are HAP) are al so present in the steel wire. The iron and other components of the wire are not expected to be released to emissions in a typical boiler. Rather, the wire ends up in the bottom ash such that, according to one commenter, the metal can be recovered. See the 2011NHSM Final Rule (76 FR 15456) for a discussion in the response to comments on the metal wire components and how the wire is considered to be a handling concern versus a concern as contaminant with potential emissions.
NOTE: non-detect values are listed as ND.Page 7 of 10 

### B. Meaningful Heating Value

Scrap tires have a high energy content ranging from 12,000 – 16,000 Btu/lb. This is higher than
solid traditional fuels. The 2011 NHSM Final Rule suggests that heating values above 5,000 Btu’s have meaningful heating value (although combustors may demonstrate that some values below 5,000 Btu/lb could still have meaningful heating value). Please refer to the 2011 NHSM
Final Rule for a full discussion. 15



### C. Managed as a Valuable Commodity

Refer to the 2011 NHSM Final Rule and the 2011 NHSM Proposed Rule for a discussion of how scrap tires are managed as a valuable commodity under established tire collection programs. “Established tire collection program” as de fined in the 2011 NHSM Final Rule was:

“ Established tire collection program means a comprehensive collection system that ensures scrap tires are not discarded and are handled as valuable commodities in accordance with section 241.3(b)(2)(i) from the point of removal from the vehicle through arrival at the combustion facility.”

As discussed in the 2011 NHSM Final Rule, scra p tires are considered to be managed as a valuable commodity when they are collected from vehicles under establishe d scrap tire collection programs (see 40 CFR 241.3(b)(2)(i) under the final ru le). Established tire collection programs promote the collection of scrap tires and coordinate with tire dealerships, haulers, processors, and end users. The existing tire co llection programs form an establis hed collection infrastructure. For a full discussion regarding how scrap tire s are managed as a valuable commodity under
established tire colle ction programs, see the preamble to the 2011 NHSM Final Rule.

Subsequent to the rule’s promul gation, EPA learned that factory scrap or off-specification tires are also managed under established tire collection programs as follows: 16



### • “Factory scrap” or “off-specification” tires ar e treated as a product and are contractually arranged to be collected, managed, and transported between a tire manufacturer (including retailers or other pa rties involved in the distribution and sale of new tires) and a combustor. They are also typically unde r the oversight of st ate tire programs.

• Tire manufacturers, as well as the manufactur ers’ downstream distri bution channels, have contractual arrangements with combustors, typically cement kilns, due to the high heating
value and beneficial contribut ion to the cement production.

• Off-specification tires (includi ng factory scrap tires), which include whole tires and tire components that do not meet manufacturer specifications, are collected at tire manufacturing facilities or ma nufacturer’s downstream dist ribution channels—retailers and other parties involved in the dist ribution and sale of new tires.

15 See 76 FR at 15456.

16 Discussion with RMA 9-13-11, posted in EPA Docket ID EPA-HQ-RCRA-2008-0329

.Page 8 of 10 

### • If at any point in the process, a tire component or whole tire is not suitable for use as a vehicle tire, it is separa ted from the other tire components (o r whole tires) and is stored in a protected environment in order to accumula te a sufficient quantity for shipment. The management of these tires is tightly cont rolled. Proprietary information could be collected by competitors by anal yzing the factory scrap tire components, particularly from the uncured components (not yet vulcani zed through heat and pressure), so the tires are stored in a safe manner, in part, to prevent theft.

• These tires are generated at tire manufactur ers (including retailer s or other parties
involved in the distribution a nd sale of new tires). The term “tire manufacturers” is broadly interpreted to include retailers and other parties that are involved in the
distribution and sa le of new tires.

Based on this new information—that is, that factor y scrap tires and off-speci fication tires are also managed as a valuable commodity under establis hed tire collection programs, the Agency is proposing to modify the definition of “Establish ed Tire Collection Program” as follows:

“ Established tire collection program means a comprehensive collection system or contractual arrangement that ensures scrap tires are not discarded and are handled as valuable commodities from the point of removal from the vehicle or th e point at which they ar e generated at a tire manufacture (including retailers or other parties involved in th e distribution and sale of new tires) through arrival at the combustion facility.” 17

17 In a August 5, 2011 letter to Ms. Tr acey J. Norberg, the Agency stated, “A s we discussed in the preamble to the NHSM final rule, the intent of the requirement to be “remove d from vehicles” is to distinguish these tires from those that were previously abandoned in waste piles—thus, discarded. Although off-spec tires are not removed from vehicles, you have indicated that these off-spec tires are managed as part of a comprehensive collection system that ensure they are not discarded, and are handled as a valuable commodity. Based on your assertions, we believe that off-spec tires that are managed by the manufacturer and transferred to a combustor fit within the intent of the regulatory requirement codified in 40 CFR 241.3(b)(2)(i) and the definition of “established tire collection program.”Page 9 of 10 

### 3. Pulp and Paper Sludge

Sludges, both primary and secondary, are produce d from wastewater treatment of process effluents from pulp and paper mills. Primar y sludges originate from primary wastewater treatment operations (i.e., sedimentation or prim ary clarification operati ons) and consist of wood fiber and inorganic materials, while seconda ry sludges come from secondary/biological treatment operations and are composed largely of microbial biomass.

A. Contaminants

Table 4: Contaminants in Pulp and P aper Sludges Compared to Coal and Wood

CONTAMINANT CONCENTRATIONS (in Parts Per Million by Weight)

Range of Pulp and Paper Sludge Values Range of Traditional Fuel Values for
Solid Fuels (EPA data unless otherwise noted) 3

Materials
Characterization Paper Data 1 AF&PA Data 2
(Submitted after the
2011 NHSM Final Rule) Coal Wood/Clean
Cellulosic Biomass

Arsenic 1.64 ND – 38 ND – 174 ND – 298

Beryllium 0.032 ND – 0.59 ND – 206 ND – 10

Cadmium 0.3 – 1.38 ND – 4.7 ND – 19 ND – 17

Chlorine 79 24 – 4800 ND – 9,080 ND – 5,400

Fluorine 24 - ND – 178 ND – 300 4

Mercury ND - 0.6 ND – 0.5 ND – 3.1 ND – 1.1

Nitrogen 40 – 44,000 - 13,600 – 54,000 200 – 39,500 4

Selenium ND ND – 1.91 ND – 74.3 ND – 9.0

Sulfur 5 – 10,000 - 740 – 61,300 ND – 8,700 4

Chromium 0.4 – 14.7 2 – 44 ND – 168 ND – 340

Lead 2 - 7 0.3 – 169.5 ND – 148 ND – 340 4

Manganese 13 - 174 0.1 – 1600 ND – 512 ND – 15,800

Nickel 0.4 - 16 1.6 – 159 ND - 730 ND - 540 4

Sources &Notes: 1. Materials Characterization Paper in Support of Final Rulemaking Identification of Non-Hazardous Secondary Materials that are Solid Waste: Biomass – Forest – Derived Biomass and Pulp and Paper Residues, February 3, 2011. 2. AFPA - NHSM Fuel Contaminant Analysis submitted 4/11/2011. 3. USEPA, Office of Air Quality Planning and Standards (OAQPS), Boiler 2011 Database and CISWI 2011 Database, available at http://www.epa.gov/ttn/atw/boiler/boilerpg.html#TECH and http://www.epa.gov/ttn/atw/1 29/ciwi/ciwipg.html#TECH respectively. 4. Energy Research Centre for the Netherlands, Phyllis Biomass database. http://www.ecn.nl/phyllis
NOTE: non-detect values are listed as ND



### As discussed in the 2011 NHSM Final Rule (76 FR 15488), the information in Table 4 indicates that these non-hazardous secondary materials contain contaminant le vels that are comparable to or lower than those levels in coal or wood, and thus meet the contaminant legitimacy criterion.Page 10 of 10 

### EPA anticipates that types of pul p and paper sludge routinely m eet the contaminant legitimacy
criteria. While commenters on the 2010 NHSM Pr oposed Rule compared contaminant levels in pulp and paper sludges to those in coal and found lower levels, we also found it appropriate to compare the contaminant concentrations to untreated wood/biomass material since these materials are (or can be) burned in pulp and paper mills. Since levels of chlorine in untreated wood/biomass are as high as 11,890 ppm, even the high end of the range of chlorine in pulp and paper sludges would be c onsidered comparable.

As indicated in the proposed rule, there is one sa mple in the submitted data set with a chlorine concentration of 16,550 ppm. However, since th is was the only sample with such a high concentration of chlorine, we do not believe that it is representative of pulp and paper sludges generally.

B. Meaningful Heating Value

Data from the Boiler/CISWI Database 18 

### established for those rules indicate that Btu/lb values exceeded 5,000 Btu/lb for pulp and paper sludge meas ured on a dry weight basis. Thus, while pulp and paper sludge can have a heating value below 5000 Btu/lb, even on a dry basis, pulp and paper mills do try to improve the heating valu e through dewatering. Accordingly, as discussed in the 2011 NHSM Final Rule, pulp and paper sl udges meet the meaningful heating value legitimacy criterion when dewatered.

C. Managed as a Valuable Commodity

Pulp and paper sludges are handle d promptly (i.e., not stored fo r long periods of time and are contained in storage units along with traditional fuels (such as wood and bark), and thus, are managed similar to traditional fuels—aka, a valuable commodity. The 2011 NHSM Final Rule provided additional information on the management of the pulp and paper sludge. 19



### As discussed in the 2011 NHSM Proposed Rule, EPA believes that pulp and paper sludges are managed as a valuable commodity.

18 USEPA, Office of Air Quality Planning and Stan dards (OAQPS), Boiler 2011 Database and CISWI 2011 Database, available at http://www.epa.gov/ttn/atw/boiler/boilerpg.html#TECH and http://www.epa.gov/ttn/atw/1 29/ciwi/ciwipg.html#TECH respectively.

19 See 76 FR 15488-89, March 21, 2011.