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Resinated Wood, Scrap Tire, and Pulp/Paper Sludge 

Support Document 

for the 2011 Proposed Rulemaking; 

Identification of Non-hazardous Secondary Materials That Are Solid Waste 

EPA Docket ID: EPA-HQ-RCRA-2008-0329 / Phase: Proposed Rule (2011) 

November 22, 2011

=============================================================== 

This document was developed in support of the 2011 proposed rulemaking, “Identification of 

Non-Hazardous Secondary Materials That Are Solid Waste” (2011 NHSM Proposed Rule). 

Specifically, this document provides information regarding the contaminant levels, heating 

values, and management practices for the non-hazardous secondary materials (NHSMs) that are 

discussed in the 2011 NHSM Proposed Rule for: (1) resinated wood; (2) scrap tires; and (3) pulp 

and paper sludge. These NHSMs were assessed based on all information available to the Agency 

at the time of the proposed rulemaking. 

 
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1. Resinated Wood

Resinated wood are wood products (containing resin adhesives) derived from primary and 

secondary wood products manufacturing and comprised 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 (MDF), particleboard, plywood, and oriented strand 

board (OSB). 

Resinated wood is highly valued within the wood products industry for its high fuel value 

relative to other wood fuels generated and burned at these facilities for energy recovery. Many 

facilities rely on mixing of these low moisture content wood materials with higher moisture 

materials. Resinated wood residuals are routinely transferred between either intra- or intercompany facilities and used as either “furnish” (i.e., raw materials) or fuel at the receiving 

facilities. The material being transferred off-site is used and handled in the same manner that 

resinated wood residuals are used and handled when generated on-site. 

A. Contaminants 

The composition of resinated wood residuals can vary widely depending on the type of wood and 

the adhesives used. In general, engineered wood is comprised of at least 90 percent wood, and 

often contains formaldehyde, a common resin. Table 1 contains sample composition information 

for an engineered wood trim product. Table 2 contains data on other contaminants contained in 

resinated wood compared to coal and wood. 

Table 1: Common Composition of Engineered Wood Trim1

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 resinated wood typically contains between 92 and 100 

percent wood, and 0 to 8 percent formaldehyde.2

 

 

1 Collins Wood. “Material Safety Data Sheet: Wood Dust,” 2005, Accessed on April 15, 2009 at: 

http://www.collinswood.com/WoodProducts/Resources/MSDS_TruWood_Trim.pdf. 2

 Universal Forest Products, Inc. “Material Safety Data Sheet: Wood Dust,” 2005. Accessed on April 15, 2009 at: 

http://www.ufpi.com/literature/wooddust-165.pdf. 
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Table 2: Contaminants in Resinated Wood Compared to Coal and Wood 

CONTAMINANT CONCENTRATIONS (in Parts Per Million by Weight)

 

Range of Resinated Wood Values1 Range of Traditional Fuel Values for 

Solid Fuels (EPA data unless otherwise noted)3

 

Contaminant 

Concentrations 

for Sander Dust 

with Resin2

Contaminant 

Concentrations for 

Panel Trim2

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 – 3005

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

Nitrogen - - 13,600 – 54,000 200 – 39,5004

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

Sulfur - - 740 – 61,300 ND – 8,7004

Chromium 0.19 - 0.40 0.09 ND – 168 ND – 340 

Lead 0.20 - 0.50 < 0.2 ND – 148 ND – 3404

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

Nickel 0.15- 0.50 0.09 ND – 730 ND – 5404

Sources and Notes:

1. Data provided by AFPA in background paper entitled, “Identification of Non-Hazardous Secondary 

Materials That are Solid Waste; Final Rule (40 CFR Part 241), Implications For Forest Product Industry 

Fuels.” June 8, 2011. This document has been placed in Docket 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/129/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 regarding 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 nationwide implementation of the California Air 

Resource Board (CARB) Composite Wood Airborne Toxic Control Measure, per Public Law 

111-199 (which establishes consistent standards for wood products across the country). Since 

the rule’s promulgation, industry has provided additional data suggesting that the CARB 

standards will have a greater impact on reducing formaldehyde levels than previously 

understood, making it highly unlikely that formaldehyde 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.
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EPA has also acknowledged a general lack of data 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 promulgation, industry has provided additional data 

indicating that formaldehyde levels 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 regarding the heating value of resinated 

wood. These comments indicated that resinated wood residuals 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 information from commenters 

regarding how resinated wood is managed as a valuable commodity when it is used as a fuel.6

 

These comments indicated that resinated wood residuals are typically pneumatically 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 these residuals that the 

wood manufacturing process creates and would not be able to operate as designed without this 

material. For example, sander dust injector systems 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 another type of fuel would be significant.8 Overall, in 

composite panel manufacturing, plants typically reuse 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, stated, “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 off-site disposal of this valuable fuel. Moreover, these costs do not take into account the 

severe costs implications on all wood product facilities that 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 Composite Panel Products; Forest Products Journal 54:2, 2004; 

David C. Smith.
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2. Scrap Tires

A major use of scrap tires is as fuel, either in whole 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 handling characteristics of individual 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 input due to the high rates of heat release and the low moisture content of 

the scrap tire material. The proposed rulemaking addresses specifically scrap tires that are not 

discarded and are managed under the oversight of established tire collection programs, including 

tires removed from vehicles and off-specification tires. 

A. Contaminants 

Table 3 summarizes the contaminants in scrap tires13 and solid traditional fuels.14 

 

10 Gray, Terry. 2009, TAG Resource Recovery. Personal Communication. August 24, 2009. 11 Id. 

12 United States Environmental Protection Agency (EPA). 2008c, “Tire Derived 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 table. 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. 
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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 Fuels4 

ASTM Data1

referenced in 

the 2011 NHSM 

Final Rule 

AF&PA Data Coal and 

Wood / Clean Cellulosic 

Biomass5

Range2

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 – 3006

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 BOILER7

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

Lead 65 2.4 – 250 63.53 (52.99) ND – 3406

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/129/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 the solid fuels subcategory, which includes 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 qualities. 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 also 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. 
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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 defined 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, scrap tires are considered to be managed as a 

valuable commodity when they are collected from vehicles under established scrap tire collection 

programs (see 40 CFR 241.3(b)(2)(i) under the final rule). Established tire collection programs 

promote the collection of scrap tires and coordinate with tire dealerships, haulers, processors, and 

end users. The existing tire collection programs form an established collection infrastructure. 

For a full discussion regarding how scrap tires are managed as a valuable commodity under 

established tire collection programs, see the preamble to the 2011 NHSM Final Rule. 

Subsequent to the rule’s promulgation, 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 are treated as a product and are contractually 

arranged to be collected, managed, and transported between a tire manufacturer 

(including retailers or other parties involved in the distribution and sale of new tires) and 

a combustor. They are also typically under the oversight of state tire programs. 

• Tire manufacturers, as well as the manufacturers’ downstream distribution channels, have 

contractual arrangements with combustors, typically cement kilns, due to the high heating 

value and beneficial contribution to the cement production. 

• Off-specification tires (including factory scrap tires), which include whole tires and tire 

components that do not meet manufacturer specifications, are collected at tire 

manufacturing facilities or manufacturer’s downstream distribution channels—retailers 

and other parties involved in the distribution 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. 
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• If at any point in the process, a tire component or whole tire is not suitable for use as a 

vehicle tire, it is separated from the other tire components (or whole tires) and is stored in 

a protected environment in order to accumulate a sufficient quantity for shipment. The 

management of these tires is tightly controlled. Proprietary information could be 

collected by competitors by analyzing the factory scrap tire components, particularly 

from the uncured components (not yet vulcanized through heat and pressure), so the tires 

are stored in a safe manner, in part, to prevent theft. 

• These tires are generated at tire manufacturers (including retailers or other parties 

involved in the distribution and sale of new tires). The term “tire manufacturers” is 

broadly interpreted to include retailers and other parties that are involved in the 

distribution and sale of new tires. 

Based on this new information—that is, that factory scrap tires and off-specification tires are also 

managed as a valuable commodity under established tire collection programs, the Agency is 

proposing to modify the definition of “Established 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 the point at which they are generated at a tire 

manufacture (including retailers or other parties involved in the distribution and sale of new 

tires) through arrival at the combustion facility.”17

 

 

17 In a August 5, 2011 letter to Ms. Tracey J. Norberg, the Agency stated, “As we discussed in the preamble to the 

NHSM final rule, the intent of the requirement to be “removed 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.” 
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3. Pulp and Paper Sludge

Sludges, both primary and secondary, are produced from wastewater treatment of process 

effluents from pulp and paper mills. Primary sludges originate from primary wastewater 

treatment operations (i.e., sedimentation or primary clarification operations) and consist of wood 

fiber and inorganic materials, while secondary sludges come from secondary/biological 

treatment operations and are composed largely of microbial biomass. 

A. Contaminants 

Table 4: Contaminants in Pulp and Paper 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 Data1

AF&PA Data2

(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 – 3004

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

Nitrogen 40 – 44,000 - 13,600 – 54,000 200 – 39,5004

Selenium ND ND – 1.91 ND – 74.3 ND – 9.0 

Sulfur 5 – 10,000 - 740 – 61,300 ND – 8,7004

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

Lead 2 - 7 0.3 – 169.5 ND – 148 ND – 3404

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

Nickel 0.4 - 16 1.6 – 159 ND - 730 ND - 5404

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/129/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 levels that are comparable to 

or lower than those levels in coal or wood, and thus meet the contaminant legitimacy criterion. 
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EPA anticipates that types of pulp and paper sludge routinely meet the contaminant legitimacy 

criteria. While commenters on the 2010 NHSM Proposed 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 considered comparable. 

As indicated in the proposed rule, there is one sample in the submitted data set with a chlorine 

concentration of 16,550 ppm. However, since this 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 Database18 established for those rules indicate that Btu/lb values 

exceeded 5,000 Btu/lb for pulp and paper sludge measured 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 value through dewatering. Accordingly, as discussed 

in the 2011 NHSM Final Rule, pulp and paper sludges meet the meaningful heating value 

legitimacy criterion when dewatered. 

C. Managed as a Valuable Commodity 

Pulp and paper sludges are handled promptly (i.e., not stored for 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 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/129/ciwi/ciwipg.html#TECH respectively. 

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