Sector Notebook Project Lumber and Wood Products 

This report is one in a series of volumes published by the U.S. Environmental 

Protection Agency (EPA) to provide information of general interest regarding 

environmental issues associated with specific industrial sectors. The documents were 

developed under contract by Abt Associates (Cambridge, MA), and Booz-Allen & 

Hamilton, Inc. (McLean, VA). This publication may be purchased from the 

Superintendent of Documents, U.S. Government Printing Office. A listing of available 

Sector Notebooks and document numbers is included on the following page. 

All telephone orders should be directed to: 

Superintendent of Documents 

U.S. Government Printing Office 

Washington, DC 20402 

(202) 512-1800 

FAX (202) 512-2250 

8:00 a.m. to 4:30 p.m., EST, M-F 

Using the form provided at the end of this document, all mail orders should be 

directed to: 

U.S. Government Printing Office 

P.O. Box 371954 

Pittsburgh, PA 15250-7954 

Complimentary volumes are available to certain groups or subscribers, such as public 

and academic libraries, Federal, State, local, and foreign governments, and the media. 

For further information, and for answers to questions pertaining to these documents, 

please refer to the contact names and numbers provided within this volume. 

Electronic versions of all Sector Notebooks are available free of charge at the following 

web address: www.epa.gov/oeca/sector. Direct technical questions to the �Feedback�

button at the bottom of the web page. 

Cover photograph by Steve Delaney, U.S. EPA. 

September 1995 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

EPA/310-R-95-006

EPA Office of Compliance Sector Notebook Project 

Profile of the Lumber and Wood Products Industry 

September 1995 

Office of Compliance 

Office of Enforcement and Compliance Assurance 

U.S. Environmental Protection Agency 

401 M St., SW (MC 2221-A) 

Washington, DC 20460 

SIC Code 24 ii September 1995 
Sector Notebook Project Lumber and Wood Products 

Sector Notebook Contacts 

The Sector Notebooks were developed by the EPA�s Office of Compliance. Questions relating 

to the Sector Notebook Project can be directed to: 

Seth Heminway, Coordinator, Sector Notebook Project

US EPA Office of Compliance

401 M St., SW (2223-A)

Washington, DC 20460

(202) 564-7017

Questions and comments regarding the individual documents can be directed to the 

appropriate specialists listed below. 

Document Number Industry 

EPA/310-R-95-001. Dry Cleaning Industry

EPA/310-R-95-002. Electronics and Computer Industry*

EPA/310-R-95-003. Wood Furniture and Fixtures Industry

EPA/310-R-95-004. Inorganic Chemical Industry*

EPA/310-R-95-005. Iron and Steel Industry

EPA/310-R-95-006. Lumber and Wood Products Industry

EPA/310-R-95-007. Fabricated Metal Products Industry*

EPA/310-R-95-008. Metal Mining Industry

EPA/310-R-95-009. Motor Vehicle Assembly Industry

EPA/310-R-95-010. Nonferrous Metals Industry

EPA/310-R-95-011. Non-Fuel, Non-Metal Mining Industry

EPA/310-R-95-012. Organic Chemical Industry*

EPA/310-R-95-013. Petroleum Refining Industry

EPA/310-R-95-014. Printing Industry

EPA/310-R-95-015. Pulp and Paper Industry

EPA/310-R-95-016. Rubber and Plastic Industry

EPA/310-R-95-017. Stone, Clay, Glass, and Concrete Industry

EPA/310-R-95-018. Transportation Equipment Cleaning Ind.

EPA/310-R-97-001. Air Transportation Industry

EPA/310-R-97-002. Ground Transportation Industry

EPA/310-R-97-003. Water Transportation Industry

EPA/310-R-97-004. Metal Casting Industry

EPA/310-R-97-005. Pharmaceuticals Industry

EPA/310-R-97-006. Plastic Resin and Man-made Fiber Ind.

EPA/310-R-97-007. Fossil Fuel Electric Power Generation Ind.

EPA/310-R-97-008. Shipbuilding and Repair Industry

EPA/310-R-97-009. Textile Industry

EPA/310-R-97-010. Sector Notebook Data Refresh-1997

EPA/310-R-98-001. Aerospace Industry

EPA/310-R-98-002. Agricultural Chemical, Pesticide, and

Fertilizer Industry

EPA/310-R-98-003. Agricultural Crop Production Industry

EPA/310-R-98-004. Agricultural Livestock Production Ind.

EPA/310-R-98-005. Oil and Gas Exploration and Production

Industry

EPA/310-R-98-008. Local Government Operations

Contact Phone (202) 

Joyce Chandler 564-7073 

Steve Hoover 564-7007 

Bob Marshall 564-7021 

Walter DeRieux 564-7067 

Maria Malave 564-7027 

Seth Heminway 564-7017 

Scott Throwe 564-7013 

Jane Engert 564-5021 

Anthony Raia 564-6045 

Jane Engert 564-5021 

Rob Lischinsky 564-2628 

Walter DeRieux 564-7067 

Tom Ripp 564-7003 

Ginger Gotliffe 564-7072 

Seth Heminway 564-7017 

Maria Malave 564-7027 

Scott Throwe 564-7013 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Jane Engert 564-5021 

Emily Chow 564-7071 

Sally Sasnett 564-7074 

Rafael Sanchez 564-7028 

Anthony Raia 564-6045 

Belinda Breidenbach 564-7022 

Seth Heminway 564-7017 

Anthony Raia 564-6045 

Amy Porter 564-4149 

Ginah Mortensen (913)551-7864 

Ginah Mortensen (913)551-7864 

Dan Chadwick 564-7054 

John Dombrowski 564-7036 

September 1995 iii SIC Code 24
Lumber and Wood Products Sector Notebook Project 

*Spanish translations available. 

SIC Code 24 iv September 1995
Sector Notebook Project Lumber and Wood Products 

LUMBER AND WOOD PRODUCTS

(SIC 24)

TABLE OF CONTENTS

Page

EXHIBITS INDEX.................................................................................................................... vi

LIST OF ACRONYMS............................................................................................................ viii

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT.......................................1

I.A. Summary of the Sector Notebook Project.........................................1

I.B. Additional Information......................................................................2

II. INTRODUCTION TO THE LUMBER AND WOOD PRODUCTS INDUSTRY.................4

II.A. Introduction, Background, and Scope of the Notebook..................4

II.B. Characterization of the Lumber and Wood Products Industry .....5

II.B.1 Industry Size and Distribution.........................................5

II.B.2. Economic Trends...............................................................9

III. INDUSTRIAL PROCESS DESCRIPTION..................................................................10

III.A. Industrial Processes in the Lumber and Wood Industry..............11

III.B. Raw Material Inputs and Pollution Outputs..................................31

III.C. Management of Chemicals in Wastestream...................................38

IV. CHEMICAL RELEASE AND TRANSFER PROFILE..................................................40

IV.A. EPA Toxic Release Inventory for the Lumber and Wood Products

Industry .............................................................................................43

IV.B. Summary of Selected Chemicals Released.....................................48

IV.C. Other Data Sources...........................................................................54

IV.D. Comparison of Toxic Release Inventory Between Selected

Industries...........................................................................................55

V. POLLUTION PREVENTION OPPORTUNITIES .......................................................58

September 1995 v SIC Code 24
Lumber and Wood Products Sector Notebook Project 

LUMBER AND WOOD PRODUCTS

(SIC 24)

TABLE OF CONTENTS (CONT'D)

Page 

VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS ...............67

VI.A. General Description of Major Statutes............................................67

VI.B. Industry Specific Requirements ......................................................78

VI.C. Pending and Proposed Regulatory Requirements ........................83

VII. COMPLIANCE AND ENFORCEMENT HISTORY ....................................................85

VII.A. Lumber and Wood Products Industry Compliance

History...............................................................................................89

VII.B. Comparison of Enforcement Activity Between Selected Industries

............................................................................................................91

VII.C. Review of Major Legal Actions .......................................................96

VII.C.1. Review of Major Cases....................................................96

VII.C.2. Supplemental Environmental Projects (SEPs) ..............97

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES......................................................99

VIII.A. Sector-Related Environmental Programs and Initiatives..............99

VIII.B. EPA Voluntary Programs ..............................................................100

VIII.C. Trade Association/Industry Sponsored Activity ........................104

VIII.C.1. Environmental Programs..............................................104

VIII.C.2. Summary of Trade Associations ..................................105

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/

BIBLIOGRAPHY ..................................................................................................111

SIC Code 24 vi September 1995 
Sector Notebook Project Lumber and Wood Products 

LUMBER AND WOOD PRODUCTS

(SIC-24)

EXHIBITS INDEX

Page 

Exhibit 1 Industry Facility Size Distribution - 1992 ....................................................6

Exhibit 2 Geographic Distribution of Industry Total Number of Lumber and Wood

Facilities per State ..........................................................................................6

Exhibit 3 Geographic Distribution of Industry Breakdown of Lumber

and Wood Facilities by State.........................................................................7

Exhibit 4 Largest U.S. Lumber and Wood Products Facilities

by Capacity (1993)......................................................................................8, 9

Exhibit 5 Example Flow Diagram for a Lumber Production Facility......................12

Exhibit 6 Veneer Dryer (Longitudinal) ......................................................................17

Exhibit 7 Example Flow Diagram of Veneer and Plywood Production .................19

Exhibit 8 Reconstituted Wood Panel Process Flow...................................................21

Exhibit 9 Schematic of Conventional Triple-Pass Drum Dryer ...............................22

Exhibit 10 Schematic of Multi-Opening Board Press ..................................................24

Exhibit 11 Example Flow Diagram for a Two-Cylinder CCA

Pressure-Treating Facility ..........................................................................29

Exhibit 12 Drip Pad with Liner.....................................................................................30

Exhibit 13 Process Materials Inputs and Pollution Outputs.......................................32

Exhibit 14 Source Reduction and Recycling Activities for SIC 24 .............................39

Exhibit 15 Top 10 TRI Releasing Lumber and Wood Product Facilities

(SIC 24 only) .................................................................................................44

Exhibit 16 Top 10 TRI Releasing Lumber and Wood Product Facilities ..................44

Exhibit 17 TRI Reporting Lumber and Wood Product Facilities

(SIC 24) by State ...........................................................................................45

September 1995 vii SIC Code 24
Lumber and Wood Products Sector Notebook Project 

LUMBER AND WOOD PRODUCTS

(SIC-24)

EXHIBITS INDEX (CONT'D)

Page 

Exhibit 18 Releases for Lumber and Wood Products (SIC 24) in TRI,

by Number of Facilities ...............................................................................46

Exhibit 19 Transfers for Lumber and Wood Products (SIC 24) in TRI,

by Number of Facilities ...............................................................................47

Exhibit 20 Pollutant Releases (Short Tons/Year) ........................................................54

Exhibit 21 Summary of the 1993 TRI Data ...................................................................56

Exhibit 22 Toxic Release Inventory Data for Selected Industries ..............................57

Exhibit 23 Five Year Enforcement and Compliance Summary for the

Lumber and Wood Industry .......................................................................90

Exhibit 24 Five Year Enforcement and Compliance Summary for Selected Industries

.......................................................................................................................92

Exhibit 25 One Year Enforcement and Compliance Summary for Selected Industries

.......................................................................................................................93

Exhibit 26 Five Year Inspection and Enforcement Summary by

Statute for Selected Industries.....................................................................94

Exhibit 27 One Year Inspection and Enforcement Summary by

Statute for Selected Industries.....................................................................95

Exhibit 28 Supplemental Environmental Projects .......................................................98

Exhibit 29 Lumber and Wood Products Facilities Participating in the

33/50 Program............................................................................................101

SIC Code 24 viii September 1995 
Sector Notebook Project Lumber and Wood Products 

LUMBER AND WOOD PRODUCTS

(SIC 24)

LIST OF ACRONYMS

ACZA - Ammoniacal Copper Zinc Arsenate

AFS - AIRS Facility Subsystem (CAA database)

AIRS - Aerometric Information Retrieval System (CAA database)

BIFs - Boilers and Industrial Furnaces (RCRA)

CAA - Clean Air Act

CAAA - Clean Air Act Amendments of 1990

CCA - Chromated Copper Arsenate

CERCLA - Comprehensive Environmental Response, Compensation and Liability

Act 

CERCLIS - CERCLA Information System 

CFCs - Chlorofluorocarbons 

CO - Carbon Monoxide 

CWA - Clean Water Act 

D&B - Dun and Bradstreet Marketing Index 

EPA - United States Environmental Protection Agency 

FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act 

FINDS - Facility Indexing System 

HAPs - Hazardous Air Pollutants (CAA) 

HB - Hardboard 

IDEA - Integrated Data for Enforcement Analysis (Enforcement Database) 

LDR - Land Disposal Restrictions (RCRA) 

LVL - Laminated Veneer Lumber 

MACT - Maximum Achievable Control Technology (CAA) 

MDI - Methylenediphenyl Diisocyanate 

MDF - Medium density Fiberboard 

NAAQS - National Ambient Air Quality Standards (CAA) 

NaOH - Sodium Hydroxide 

NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA) 

NCP - National Oil and Hazardous Substances Pollution Contingency Plan 

NESHAP - National Emission Standards for Hazardous Air Pollutants 

NSPS - New Source Performance Standards (CAA) 

NOx - Nitrous Oxides 

NPDES - National Pollution Discharge Elimination System (CWA)

OAR - Office of Air and Radiation

OPA - Oil Pollution Act

OECA - Office of Enforcement and Compliance Assurance

OPPTS - Office of Prevention, Pesticides, and Toxic Substances

OSB - Oriented Strand Board

OSW - Office of Solid Waste

OSWER - Office of Solid Waste and Emergency Response

September 1995 ix SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

LUMBER AND WOOD PRODUCTS

(SIC 24)

LIST OF ACRONYMS (CONT'D)

OW - Office of Water

P2 - Pollution Prevention

PB - Particleboard

PCP - Pentachlorophenol

PCS - Permit Compliance System (CWA Database)

PF - Phenol-Formaldehyde

PM - Particulate Matter

RCRA - Resource Conservation and Recovery Act

RCRIS - RCRA Information System

SDWA - Safe Drinking Water Act

SOx - Sulfur Oxides

TGNMO Total Gaseous Nonmethane Organics

TRI - Toxic Release Inventory

TRIS - Toxic Chemical Release Inventory System

TSCA - Toxic Substances Control Act

UF - Urea-Formaldehyde

UIC - Underground Injection Control (SDWA)

UST - Underground Storage Tanks (RCRA)

VOCs - Volatile Organic Compounds

SIC Code 24 x September 1995 
Sector Notebook Project Lumber and Wood Products 

LUMBER AND WOOD PRODUCTS

(SIC 24)

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 

I.A. Summary of the Sector Notebook Project 

Environmental policies based upon comprehensive analysis of air, water, 

and land pollution are an inevitable and logical supplement to traditional 

single-media approaches to environmental protection. Environmental 

regulatory agencies are beginning to embrace comprehensive, multistatute solutions to facility permitting, enforcement and compliance 

assurance, education/outreach, research, and regulatory development 

issues. The central concepts driving the new policy direction are that 

pollutant releases to each environmental medium (air, water, and land) 

affect each other, and that environmental strategies must actively identify 

and address these inter-relationships by designing policies for the "whole" 

facility. One way to achieve a whole facility focus is to design 

environmental policies for similar industrial facilities. By doing so, 

environmental concerns that are common to the manufacturing of similar 

products can be addressed in a comprehensive manner. Recognition of 

the need to develop the industrial "sector-based” approach within the 

EPA Office of Compliance led to the creation of this document. 

The Sector Notebook Project was initiated by the Office of Compliance 

within the Office of Enforcement and Compliance Assurance (OECA) to 

provide its staff and managers with summary information for eighteen 

specific industrial sectors. As other EPA offices, States, the regulated 

community, environmental groups, and the public became interested in 

this project, the scope of the original project was expanded. The ability to 

design comprehensive, common sense environmental protection measures 

for specific industries is dependent on knowledge of several inter-related 

topics. For the purposes of this project, the key elements chosen for 

inclusion are: general industry information (economic and geographic); a 

description of industrial processes; pollution outputs; pollution 

prevention opportunities; Federal statutory and regulatory framework; 

compliance history; and a description of partnerships that have been 

formed between regulatory agencies, the regulated community, and the 

public. 

September 1995 1 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

For any given industry, each topic listed above could alone be the subject 

of a lengthy volume. However, in order to produce a manageable 

document, this project focuses on providing summary information for 

each topic. This format provides the reader with a synopsis of each issue, 

and references where more in-depth information is available. Text within 

each profile was researched from a variety of sources, and was usually 

condensed from more detailed sources pertaining to specific topics. This 

approach allows for a wide coverage of activities that can be further 

explored based upon the citations and references listed at the end of this 

profile. As a check on the information included, each notebook went 

through an external review process. The Office of Compliance 

appreciates the efforts of all those that participated in this process and 

enabled us to develop more complete, accurate, and up-to-date 

summaries. Many of those who reviewed this notebook are listed as 

contacts in Section IX and may be sources of additional information. The 

individuals and groups on this list do not necessarily concur with all 

statements within this notebook. 

I.B. Additional Information 

Providing Comments 

OECA's Office of Compliance plans to periodically review and update the 

notebooks and will make these updates available both in hard copy and 

electronically. If you have any comments on the existing notebook, or if 

you would like to provide additional information, please send a hard 

copy and computer disk to the EPA Office of Compliance, Sector 

Notebook Project, 401 M St., SW (2223-A), Washington, DC 20460. 

Comments can also be uploaded to the Enviro$en$e Bulletin Board or the 

Enviro$en$e World Wide Web for general access to all users of the 

system. Follow instructions in Appendix A for accessing these data 

systems. Once you have logged in, procedures for uploading text are 

available from the on-line Enviro$en$e Help System. 

Adapting Notebooks to Particular Needs 

The scope of the existing notebooks reflect an approximation of the 

relative national occurrence of facility types that occur within each sector. 

In many instances, industries within specific geographic regions or States 

may have unique characteristics that are not fully captured in these 

profiles. For this reason, the Office of Compliance encourages State and 

local environmental agencies and other groups to supplement or repackage the information included in this notebook to include more 

SIC Code 24 2 September 1995 
Sector Notebook Project Lumber and Wood Products 

specific industrial and regulatory information that may be available. 

Additionally, interested States may want to supplement the "Summary of 

Applicable Federal Statutes and Regulations" section with State and local 

requirements. Compliance or technical assistance providers may also 

want to develop the "Pollution Prevention" section in more detail. Please 

contact the appropriate specialist listed on the opening page of this 

notebook if your office is interested in assisting us in the further 

development of the information or policies addressed within this volume. 

If you are interested in assisting in the development of new notebooks for 

sectors not covered in the original eighteen, please contact the Office of 

Compliance at 202-564-2395. 

September 1995 3 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

II. INTRODUCTION TO THE LUMBER AND WOOD PRODUCTS INDUSTRY 

II.A. Introduction, Background, and Scope of the Notebook 

This section provides background information on the size, geographic 

distribution, employment, production, sales, and economic condition of 

the lumber and wood products industry. The type of facilities described 

within the document are also described in terms of their Standard 

Industrial Classification (SIC) codes. Additionally, this section contains a 

list of the largest companies in terms of sales. 

The lumber and wood products industry includes establishments 

engaged in cutting timber and pulpwood; sawmills, lath mills, shingle 

mills, cooperage stock mills (wooden casks or tubs), planing mills, 

plywood mills; and establishments engaged in manufacturing finished 

articles made entirely or mainly of wood or related materials such as 

reconstituted wood panel products manufacturers. The categorization 

corresponds to the Standard Industrial Classification (SIC) code 24 

established by Department of Commerce's Bureau of the Census to track 

the flow of goods and services within the economy. It should be noted 

that silviculture (development and care of forests) and the preparation of 

forested areas for logging is covered by SIC 08 (forestry) and is not 

addressed in this industry profile. 

In this profile, the industry's processes are divided into four general 

groups: logging timber; producing lumber; panel products and wood 

preserving. The Bureau of the Census estimates that in 1992, employment 

in these principal categories totaled approximately 306,700 (See Exhibit 1 

for facility employment size distribution). This does not include the 

additional employment generated by the wood container, structure wood 

member, wood kitchen cabinet, and wood building/mobile home sectors. 

Shipments increased less than one percent in 1993, to an estimated $78.1 

billion. Sawmills and planing mills (SIC 242) accounted for $24.8 billion 

(31 percent) of industry shipments in 1993. Logging (SIC 241) added an 

additional $15.6 billion (17.8 percent). 

The Department of Commerce provides the following three-digit 

breakout for lumber and wood products industries in SIC 24: 

SIC 241 - Logging

SIC 242 - Sawmills and Planing Mills

SIC 243 - Millwork, Veneer, Plywood, and Structural Wood

Members 

SIC 244 - Wood Containers 

SIC Code 24 4 September 1995 
Sector Notebook Project Lumber and Wood Products 

SIC 245 - Wood Buildings and Mobile Homes 

SIC 249 - Miscellaneous Wood Products. 

The main end use market for the industry's products is the new 

construction and remodeling sectors. 

This profile covers logging, sawn lumber production, panel products 

including veneer and plywood manufacture and reconstituted wood 

panel manufacture (which includes particleboard (PB), hardboard (HB), 

medium density fiberboard (MDF), and oriented strand board(OSB)), 

engineered lumber, and wood preserving. Each of these are discussed in 

greater detail later in the profile. This profile does not address 

production processes, pollution outputs, or regulatory information for the 

following three-digit industries contained in SIC 24: Wood Containers 

(SIC 244), Wood Buildings and Mobile Homes (SIC 245), and some areas 

of Miscellaneous Wood Products (SIC 249). 

II.B. Characterization of the Lumber and Wood Products Industry 

The discussion of the characterization of the lumber and wood products 

industry is divided into the following topics: industry size and 

geographic distribution; identification of the largest U.S. facilities in the 

industry by capacity; and industry economic trends. 

II.B.1. Industry Size and Distribution 

Variation in facility counts occur across data sources due to many factors, 

including reporting and definition differences. This document does not 

attempt to reconcile these differences, but rather reports the data as they 

are maintained by each source. 

Geographic Distribution 

Most of the wood products industry is concentrated in the Pacific 

Northwest and the Southeast. However, concentrations are also found 

across the Midwest, the Northeast, and in Appalachia (See Exhibits 2 and 

3). Approximately 1/3 of the U.S. is forested. Of this forested area, twothirds (480 million acres) contain at least 20 cubic feet of commercially 

usable wood per year per acre, the threshold for determining whether 

timberland could be commercially productive. The area east of the 

Mississippi still contains a significant amount of forested acreage; 155 

million acres are in the Northern States and 195 million acres are in the 

South. About 130 million acres of forested land is in Western States. 

September 1995 5 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 4 illustrates the largest lumber and wood products facilities in the 

U.S. by capacity. 

SIC Code 24 6 September 1995
Sector Notebook Project Lumber and Wood Products 

Exhibit 1 

Industry Facility Size Distribution - 1992 

Type of Facility 

Facilities 

with 1 to 19 

employees 

Facilities 

with 20 to 99 

employees 

Facilities with 

100 or more 

employees Total 

SIC 2411 - Logging 12,283 691 36 13,010 

SIC 2421 - Lumber 4,400 1,283 321 6,004 

SICs 2435 & 2436 -

Hardwood, Softwood 

Plywood, Veneer 

147 208 164 519 

SIC 2491 - Wood 

Preserving 

307 168 11 486 

SIC 2493 -

Reconstituted Wood 

Products 

108 80 100 288 

Source: Based on 1992 Bureau of the Census Data. 

Exhibit 2

Geographic Distribution of Industry

Total Number of Lumber and Wood Products Facilities per State*

1,782 

2,110 

2,671 

66 

292 

158 

553 

457 

101 

311 

143 

1,179 

68 

HI 41 AK 

33 

65 

92 

131 

145 

572 

174 

634 

842 

678 

964 1,543 

831 

483 

566 691 

1,042 

1,071 

876 

436 1,199 

1,858 

897 

1,522 

1,368 

1,428 

1,137 

732 

372 

274 

4 

39 

344 

242 

69 

443 

Total=33,987 

Source: Based on 1987 Bureau of the Census Data. 1992 Bureau of the Census Data on 

State breakdown was not available at the time of publication. 

*Note: Exhibit represents all industries within SIC 24. 

September 1995 7 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 3

Geographic Distribution of Industry

Breakdown of Lumber and Wood Facilities by State

Type of Facility Number of Facilities Per State 

Logging AL-957, AK-37, AR-403, CA-525, FL-346, GA-796, ID-321, KY-95, 

LA-413, ME-439, MI-341, MN-176, MS-531, MT-312, NH-130, NH-130, 

NY-209, NC-677, OH-128, OR-1,293, PA-257, SC-559, TN-128, TX-297, 

VA-444, WA-597, WV-185, WI-384 

Sawmills and 

Planning Mills 

AL-212, AZ-17, AR-218, CA-278, CO-48, CT-34, FL-94, GA-216, ID-100, 

IL-75, IN-155, KY-185, LA-104, ME-141, MD-58, MA-89, MI-219, MN-96, 

MS-213, MO-237, MT-68, NH-83, NM-27, NY-231, NC-554, OH-172, 

OK-50, OR-309, PA-448, SC-126, SD-17, TN-345, TX-116, UT-26, VT-78, 

VA-370, WA-381, WV-188, WI-206, WY-28 

Millwood, Plywood 

and Structural 

Members 

AL-158, AZ-146, AR-85, CA-1,145, CO-140, CT-122, FL-661, GA-260, 

ID-66, IL-224, IN-213, IA-54, KS-70, KY-78, LA-77, ME-31, MD-86, 

MA-172, MI-192, MN-165, MS-73, MO-144, MT-30, NE-47, NV-42, 

NH-47, NJ-165, NM-62, NY-378, NC-294, OH-225, OK-49, OR-298, 

PA-315, RI-28, SC-105, SD-21, TN-153, TX-412, UT-82, VT-30, VA-185, 

WA-273, WV-26, WI-206 

Wood Containers AL-56, AR-39, CA-204, FL-37, GA-69, IL-13, IN-103, KY-71, MI-144, 

MN-36, MS-39, MO-85, NJ-46, NY-82, NC-80, OH-172, OR-26, PA-155, 

SC-38, TN-87, TX-85, VA-54, WA-30, WI-83 

Wood Buildings and 

Mobile Homes 

AL-46, AZ-20, CA-87, CO-11, DE-2, FL-68, GA-53, ID-13, IL-25, IN-55, 

KS-12, ME-12, MD-13, MA-18, MI-34, MN-20, MS-12, MO-21, NE-7, 

NH-20, NY-27, NC-51, OH-36, OR-23, PA-72, TN-32, TX-74, VA-31, 

WA-18, WI-34 

Miscellaneous Wood 

Products 

AL-113, AR-84, CA-432, FL-161, GA-128, ID-43, IL-147, IN-96, IA-27, 

KY-46, LA-58, ME-91, MD-36, MA-93, MI-141, MN-79, MS-96, MO-102, 

NH-72, NJ-71, NM-16, NY-210, NC-202, OH-143, OK-26, OR-159, 

PA-181, SC-68, TN-88, TX-195, VT-115, WA-123, WV-36, WI-119 

Source: Based on 1987 Bureau of the Census Data.*

*1992 Bureau of Census Data on State breakdown was not available at the time of publication.

SIC Code 24 8 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 4

Largest U.S. Lumber and Wood Products Facilities by Capacity (1993)

Lumber Production 

1. Weyerhaeuser Co. 

2. Georgia-Pacific Corp. 

3. Louisiana-Pacific Corp. 

4. Sierra Pacific Industries 

5. International Paper Co. 

6. Boise Cascade Corp. 

7. Pope & Talbot Inc. 

8. MacMillan Bloedel Ltd. 

9. WTD Industries Inc. 

10. Simpson Timber Co. 

Softwood Plywood 

1. Georgia-Pacific Corp. 

2. Willamette Industries Inc. 

3. Boise Cascade Corp. 

4. Louisiana-Pacific Corp. 

5. Roseburg Forest Products Co. 

6. Weyerhaeuser Co. 

7. Champion International 

8. International Paper Co. 

9. Stimson Lumber Co. 

10. Stone Forest Industries Inc. 

Particleboard 

1. Georgia-Pacific Corp. 

2. Willamette Industries Inc. 

3. Weyerhaeuser Co. 

4. Louisiana-Pacific Corp. 

5. Temple-Inland Forest 

Products Corp. 

6. Roseburg Forest Products Co. 

7. Masonite Corp. 

8. Allegheny Particleboard Corp. 

9. Boise Cascade Corp. 

10. Timber Products Co. 

Softwood Veneer 

1. Scotch Plywood Co. of Alabama 

2. Stone Forest Industries Inc. 

3. Freres Lumber Co. Inc. 

4. Sun Studs Inc. 

5. Plum Creek Manufacturing, L.P. 

6. Hunt Plywood Co. Inc. 

7. Omak Wood Products, Inc. 

8. Roseburg Forest Products 

9. Green Veneer Inc. 

10. WTD Industries Inc. 

OSB/Waferboard 

1. Louisiana-Pacific Corp. 

2. Potlatch Corp. 

3. Georgia-Pacific Corp. 

4. Weyerhaeuser Co. 

5. J.M. Huber Corp. 

6. Norbord Industries 

7. Roy O. Martin Lumber Co. Inc. 

8. International Paper Co. 

9. Langdale Forest Products Co. 

Medium-density Fiberboard 

1. Willamette Industries Inc. 

2. Louisiana-Pacific Corp. 

3. Medite Corp. 

4. Masonite Corp. 

5. Plum Creek Manufacturing, L.P. 

6. Georgia-Pacific Corp. 

7. Sierra-Pine, Ltd. 

8. Weyerhaeuser Co. 

9. Norbord Industries 

10. Bassett Industries 

Source: American Forest & Paper Association, Wood Technology's 1994-95 North American Factbook. 

September 1995 9 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 4 (cont'd)

Largest U.S. Lumber and Wood Products Facilities by Capacity (1993)

Hardboard 

1. Georgia-Pacific Corp. 

2. Masonite Corp. 

3. Weyerhaeuser Co. 

4. Wood Fiber Industries Inc. 

5. Louisiana-Pacific Corp. 

6. Stimson Lumber Co. 

7. Evanite Fiber Corp. 

8. Dee Forest Products Inc. 

Laminated Veneer 

Lumber, I-joists 

1. Louisiana-Pacific Corp. 

2. Willamette Industries Inc. 

3. Georgia-Pacific Corp. 

4. Tecton Laminates 

5. South Coast Lumber Co. 

Parallel, Laminated Strand 

Lumber 

1. Trus Joist MacMillian 

Glulam Beams 

1. Willamette Industries Inc. 

2. Anthony Forest Products Co. 

Panelboard 

1. Georgia-Pacific Corp. 

Composite Panels 

1. Oregon Strand Board Co. 

Source: American Forest & Paper Association, Wood Technology's 1994-95 North American Factbook. 

II.B.2. Economic Trends 

The lumber and wood products industry is heavily dependent upon the 

health of the U.S. residential construction and household furniture 

industries. Lumber and wood product shipments increased less than one 

percent in 1993 and this low level of growth is expected to continue in 

1994. Domestic wood products shipments over the next five years are 

expected to remain constant. 

Since the mid-1980's, timber harvests from publicly-owned lands have 

declined by more than 50 percent. The decline is due to new land 

management policies by the Federal government that have reduced the 

amount of land available for harvesting. 

According to the Hardwood Plywood and Veneer Association, there has 

been a substantial decline in the use of hardwood plywood prefinished 

wall paneling due to shifts in consumer preference, a decline in 

SIC Code 24 10 September 1995 
Sector Notebook Project Lumber and Wood Products 

promotion and advertising by major manufacturers, changes in the cost of 

plywood paneling related to gypsum wallboard, and the public's concern 

about real or perceived formaldehyde releases from wall paneling. With 

respect to reconstituted wood panel products shipments of PB, OSB, and 

MDF are all increasing rapidly. U.S. shipments of MDF were at record 

levels in 1993. 

The engineered lumber sector of the industry (reconstituted wood 

substitutes for sawn lumber), is currently seeing a rapid rise in 

production. The production of glulam beams and laminated veneer 

lumber (LVL), two types of engineered lumber, is increasing rapidly and 

this increased growth is expected to continue. By 2003, the North 

American output of LVL is expected to reach 98 million ft3 (the American 

Plywood Association's production estimate for LVL in 1995 is 33 million 

ft3). 

September 1995 11 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

III. INDUSTRIAL PROCESS DESCRIPTION 

This section describes the major industrial processes within the lumber 

and wood products industry, including the materials and equipment 

used, and the processes employed. The section is designed for those 

interested in gaining a general understanding of the industry, and for 

those interested in the inter-relationship between the industrial process 

and the topics described in subsequent sections of this profile -- pollutant 

outputs, pollution prevention opportunities, and Federal regulations. 

This section does not attempt to replicate published engineering 

information that is available for this industry. Refer to Section IX for a list 

of reference documents that are available. 

This section specifically contains a description of commonly used 

production processes, associated raw materials, the by-products produced 

or released, and the materials either recycled or transferred off-site. This 

discussion, coupled with schematic drawings of the identified processes, 

provide a concise description of where wastes may be produced in the 

process. This section also describes the potential fate (air, water, land) of 

these waste products. 

III.A. Industrial Processes in the Lumber and Wood Industry 

This section describes the major processes used by the lumber and wood 

products industry. It is divided into the following sections: logging, 

sawn lumber, paneling (including veneer and plywood and reconstituted 

wood panel products), engineered lumber, and wood preserving. 

Information for these descriptions was obtained from a variety of sources 

including Characterization of Manufacturing Processes, Emissions, and 

Pollution Prevention Options for the Composite Wood Industry (Martin and 

Northeim, 1995), Forest Products and Wood Science (Haygreen and Bowyer, 

1989), and Guide to Pollution Prevention: Wood Preserving Industry (U.S. 

EPA, 1993). 

SIC Code 24 12 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 5

Example Flow Diagram For a Lumber Production Facility

To Customer 

To Customer 

To Customer 

To Customer 

To Customer 

To Customer To Customer 

SAW 

(SAWMILL) 

ROUGH 

LUMBER 

SILO 

PM 

SORTER/ 

STACKER 

CO1 

(CYCLONE) WOOD WASTE WOOD WASTE 

ROUGH 

LUMBER 

SILO 

BO1 

(BOILER) 

STEAM 

KO2 

(DRY KILN) 

KO1 

(DIRECT FIRED 

DRY KLIN) 

CO, VOC, 

NOX, SOX, 

PM 

DRIED LUMBER 

CO, VOC, 

NOX, SOX, 

PM 

CO2 SHAVINGS

(CYCLONE) 

PM 

FUGITIVE 

EMISSIONS 

PM 

(PLANER MILL) UNTREATED 

PLANED LUMBER 

PLANED 

LUMBER 

CO4 

(CYCLONE) 

PM 

PURCHASED 

LUMBER 

SANDERDUST 

TRW BLOCKS 

CH1 

(CHIPPER) 

CO3 CHIPS

(CYCLONE) 

FUGITIVE 

EMISSIONS 

PURCHASED 

LUMBER 

TRT 

(TREATMENT PLANT) 

TREATED LUMBER 

RMN 

(REMANUFACTORING) 

FUGITIVE 

EMISSIONS 

Source: Southern Lumber Manufacturing Association, 1995. 

Logging 

Timber harvesting may be accomplished by either manual or mechanical 

means. However, the traditional methods of hand sawing or ax use are 

September 1995 13 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

almost never used. Chain saws powered by gasoline engines or large 

felling machines are currently used to cut down standing trees. The 

felling machines use hydraulically-activated shears that cut the tree at its 

base and transport it to a collection point. The logs are transported by 

motorized cable or by tractor to larger collection areas for transportation 

(usually by motor trucks or water) to the sawmill. 

Sawn Lumber 

Sawn lumber is softwood or hardwood trimmed at a sawmill and 

destined for a future use such as construction, industrial, or furniture 

products. Most of the commercially important softwood species such as 

Southern Yellow Pine, Western Pines, Western Hemlock, Spruce, and 

Douglas Fir grow in the South or West. Softwood boards are used 

primarily for framing light construction such as homes, schools, churches, 

and farm buildings. Hardwood species such as Maple and Oak, are 

grown and processed mainly in the Eastern portion of the U.S. and are 

used for flooring, furniture, and crating. 

Exhibit 5 illustrates the lumber production process. Logs are delivered to 

sawmills from the forest and stored in ponds or on land. Most wood is 

stored on land. Logs are sometimes stored at intermediate points 

between the forest and the sawmill. If stored on land, the logs are usually 

sprayed with water to keep them moist and prevent cracking. The raw 

logs are debarked and then cut into cants (partially cut lumber), which are 

trimmed into raw lumber. As the logs are debarked, bark is used as hog 

fuel for boilers or sold as mulch. Shavings, sawdust, and chips can also 

be used at paper mills and reconstituted wood panel manufacturing 

plants. 

The cants are cut to specific lengths or finished further depending on the 

final destination of the lumber product. Most lumber is dried to a specific 

moisture content (conditioned) through air or kiln drying. Air drying, 

which entails stickering (spacing) and stacking the cut lumber in open 

storage areas, usually requires several months to a few years. Kiln drying 

is more time efficient because it uses controlled air flow within a vented 

closed chamber to quickly dry the lumber to a specified moisture content. 

Whether lumber is air- or kiln-dried depends upon variables such as the 

moisture content of the species and the humidity of the region. 

Sawmills frequently perform surface protection operations to protect 

lumber against sapstaining that may occur during temporary storage. 

Sapstains do not attack the structural components of the wood but do 

affect the surface, coloring it with dark blue or black stains. This 

SIC Code 24 14 September 1995 
Sector Notebook Project Lumber and Wood Products 

discoloration is often objectionable to the buyer and may decrease the 

value of the wood and its acceptance of finishes. 

Surface protection is typically conducted at mills that process hardwoods; 

however, softwoods cut for export may also be surface protected. Plants 

typically treat their lumber with surface protectants only during humid 

months, depending on the region of the country in which they operate. 

Wood that is kiln-dried is not normally surface-protected. All green 

wood to be exported is protected. The most popular surface protectant 

currently used by approximately 85% of all major U.S. mills who treat 

lumber is a solution composed of 3-iodo-z-propynyl butyl carbamate 

(IPBC), didecyl dimethyl ammonium chloride (DDAC), and inert 

ingredients. The solution is diluted with water to a ratio of 35-1 for spray 

box application and 100-1 for dip tank applications. 

Three major processes are used by sawmills to apply surface protectant to 

wood: the dip process, the spray process, and the green chain process. 

Typically the sawmill will use only one process to surface protect; 

however, some plants use a combination of processes to protect lumber at 

different locations throughout a mill. Dipping is a batch process; green 

chain and spray operations are continuous processes. The process used 

influences the amount of control a plant has over the waste it generates 

during the surface protection process. 

Dip operations offer the best opportunity to control drippage since an 

owner or operator has the ability to keep the wood over the tank until it 

stops dripping. Dipping operations can lead to uncontrolled drippage 

when mills do not allow the treated loads to stop dripping before the next 

load is dipped. Lumber is dipped in horizontal bundles, and as a result, 

liquid is often trapped between pieces of wood. When forklifts remove 

the lumber, large quantities of protectant can drip from the wood onto the 

ground if the lumber is tipped. 

Unlike dipping, the spray operation is a continuous process. Individual 

pieces of lumber are fed end-to-end by chain, roller, or conveyor belt 

through a spray box. The spray box is often equipped with flexible 

brushes or curtains at both ends to isolate the formulation spray and 

minimize drippage. A drip pan is usually incorporated into the design of 

the spray box allowing formulation to return to the work tank. 

Green-chain systems represent another type of continuous operation. The 

green-chain is so-named because chains drag fresh cut (or "green") lumber 

through a tank of protectant formulation and back out again for sorting 

and grading. A dip vat containing anti-stain formulation is typically 

September 1995 15 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

located at the head of the green chain and the wood falls into this vat 

from the cutting operations. Some systems utilize wheels or rollers just 

above the formulation surface to force the wood pieces into the solution. 

As the wood is drawn from the vat and along the green chain, excess 

formulation is released from the wood onto the return drip pan. Greenchain operations are typically the least controllable with respect to 

drippage. 

Panel Products 

This section describes two classes of panel products: (1) hardwood veneer, 

softwood veneer, and plywood; and (2) reconstituted wood products. 

Hardwood Veneer and Softwood Veneer and Plywood 

Veneer is a thin sheet of wood peeled or sliced from blocks of lumber 

called flitches or logs. Veneer is glued together to form plywood. 

Hardwood found in the Western and Southern U.S. is generally used to 

manufacture hardwood plywood. Softwood logs from the Northwest and 

Eastern U.S. are used to make softwood plywood. Softwood plywood is 

primarily used for construction. Softwood veneer and plywood is 

typically used for structural and industrial applications and represents 

over 90 percent, by volume, of U.S. production. Hardwood veneer and 

plywood is used typically for decorative applications and for making 

interior paneling, components for furniture and cabinets, and specialty 

products. There are several other important differences between 

softwood plywood and hardwood plywood: softwood plywood is 

generally made with relatively thick faces (1/10” and thicker) and with 

exterior or intermediate glue (for protected construction and industrial 

uses where moderate delays in providing protection might be expected or 

conditions of high humidity and water leakage may exist). Hardwood 

plywood is made with face veneers generally 1/32” and thinner. Because 

of its nature and the use of decorative thin face veneers, the glues used for 

hardwood plywood tend to be colorless or light in color so as not to 

discolor the surfaces if the adhesive bleeds into and through the thin 

faces. While most hardwood plywood is all veneer, some is made with 

particleboard and medium density fiberboard core. 

The general processes for making softwood and hardwood plywood are 

the same: log debarking, log steaming and or soaking, veneer cutting, 

veneer drying, veneer preparation, glue application, pressing, panel 

trimming, and panel sanding. These basic processes are illustrated in 

Exhibit 7. Nevertheless, there are differences in details in these softwood 

and hardwood plywood processes. Because of its greater volume, this 

SIC Code 24 16 September 1995 
Sector Notebook Project Lumber and Wood Products 

section primarily describes softwood veneer and plywood manufacturing. 

However, it is noted where details of the manufacturing process are 

substantially different for hardwood plywood. 

Most softwood plywood plants also produce veneer. Most hardwood 

plywood plants purchase components for making plywood from outside 

sources. Logs received at the plant are debarked and cut into lengths 

appropriate for the plant's processing equipment. Almost all hardwood 

and many softwood blocks are heated prior to cutting or peeling the 

veneer to soften the wood. The cut logs are heated by steaming, soaking 

in hot water, spraying with hot water, or combinations of these methods. 

The heating time required depends on the diameter of the log, specific 

gravity, moisture content, and the temperature needed to properly peel 

that particular species of wood. 

The major methods for producing veneer are slicing and peeling. The 

majority of veneer is produced by peeling (rotary cutting) on a veneer 

lathe into sheets of uniform thickness. Slicing is used to produce 

hardwood decorative veneers from a flitch generally in thicknesses of 

1/24” and thinner, and is seldom used with softwood. In either case, the 

wood is forced under a pressure bar that slightly compresses the wood as 

it hits the cutting edge of a knife. On a rotary lathe, the block, or log 

section, continuously rotates against the knife and the pressure bar and 

peels a sheet of veneer from the heated block. 

The veneer is peeled at a rate of 300 to 800 lineal feet/min. A series of 

120-foot long trays is used in many softwood plywood plants to gently 

handle these long sheets of wood as they are peeled from the chuck. In 

softwood mills and some hardwood mills, high-speed clippers 

automatically chop the veneer ribbons to usable widths at speeds of 1500 

lineal feet/min. In hardwood mills, clipping may be done manually to 

obtain the maximum amount of clear material from the flitch. 

After the veneer is peeled and clipped, it must be dried. Two types of 

dryers are used in softwood veneer mills: roller resistant dryers, heated 

by forced air; and platen dryers, heated by steam. In older roller dryers, 

also still widely used for hardwood veneer, air is circulated through a 

zone parallel to the veneer (see Exhibit 6). Most plants built in recent 

years use jet dryers (also called impingement dryers) that direct a current 

of air, at a velocity of 2,000 to 4,000 feet/min., through small tubes on the 

surface of the veneer. 

Veneer dryers may be heated indirectly with steam, generated by a 

separate boiler, which is circulated through internal coils in contact with 

September 1995 17 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

dryer air. Dryers may also be heated directly by the combustion gases of 

a gas- or wood-fired burner. The gas-fired burner is located inside the 

dryer, whereas combustion gases from a wood-fired burner are mixed 

with recirculating dryer air in a blend box outside the dryer and then 

transported into the dryer. Veneer dryers tend to release organic aerosols, 

gaseous organic compounds, and small amounts of wood fiber into the 

atmosphere. 

Exhibit 6 

Veneer Dryer (Longitudinal) 

Source: Basic Plywood Processing. 

From the dryer, the sheets of veneer travel to a glue application station. 

Narrow pieces of hardwood veneers are often joined with an adhesive 

and/or string to maximize recovery. In the gluing process, also known as 

layup, adhesive is applied to the individual sheets of veneer which are 

later assembled into plywood. Various adhesive application systems are 

used including hard rolls, sponge rolls, curtain coaters, sprayers, and 

foam extruders. The most common application for softwood plywood is 

an air or airless spray system, which generally uses a fixed-head 

applicator capable of a 10-foot wide spray at a nozzle pressure of 300 

pounds per square inch (psi). Roller applications are most common in the 

manufacture of hardwood plywood. 

With spray systems, control of glue spreads is achieved by adjusting the 

veneer conveyor speed, or by changing the size of the spray nozzle orifice. 

Wastes generated in the layup process include adhesive waste (typically 

overspray), and off-spec plywood. 

SIC Code 24 18 September 1995 
Sector Notebook Project Lumber and Wood Products 

The phenol-formaldehyde (PF) typical in softwood plywood 

manufacturing and urea-formaldehyde (UF) adhesions typically used in 

hardwood plywood are made from resins synthesized in regional plants 

and shipped to individual plywood mills. At the mills, the resins are 

combined with extenders, fillers, catalysts, and caustic to make a glue 

mixture. The addition of these ingredients modifies the viscosity of the 

adhesive and allows it to be compatible with the glue application method 

(curtain, roll, spray, foam); allows for better adhesive distribution; 

increases the cure rate; and lowers cost. 

Following the application of glue, the panels must be pressed. The 

purpose of the press is to bring the veneers into close contact so that the 

glue layer is very thin. At this point, resin is heated to the temperature 

required for the glue to bond. Most plywood plants prepress the panels 

in a cold press at lower pressure prior to final pressing in the hot press. 

This allows the wet adhesive to "tack" the veneers together, permits easier 

loading of the hot-press, and prevents shifting of the veneers during 

loading. Pressing is usually performed in multiopening presses, which 

can produce 20 to 40 4x8-foot panels in each two to seven minute pressing 

cycle. 

One of the goals of the pressing process is to use enough pressure to bring 

the veneer surfaces together without overcompressing the wood. Less 

pressure is required if the lathe has cut smooth veneer of a uniform 

thickness. 

After pressing, stationary circular saws trim up to one inch from each side 

of the pressed plywood to produce square-edged sheets. Approximately 

20 percent of annual softwood plywood production is then sanded. Over 

90 percent of the hardwood plywood production is sanded. As sheets 

move through enclosed automatic sanders, pneumatic collectors above 

and below the plywood continuously remove the sanderdust. Sawdust in 

trimming operations is also removed by pneumatic collectors. The 

plywood trim and sawdust are burned as fuel or sold to reconstituted 

panel plants. Exhibit 7 illustrates the veneer and plywood manufacturing 

process. 

September 1995 19 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 7

Flow Diagram of Veneer and Plywood Production LOG STORAGE (LOG POND, COLD DECK, OR BOTH) LOG DEBARKING LOG STEAMING VENEER LATHE VENEER DRYER VENEER PREPARATION GLUE LINE PRESSING SANDING AND CUTTING GLUE LINE 

GASES 

SOLIDS 

LIQUIDS 

LIQUID WASTE 

OVERFLOW FROM 

LOG POND 

"GREEN END" STEAM 

CONDENSATE 

DRYER WASH AND DELUGE WATER 

EXHAUST GASES 

GLUE RESIN WATER NaOH EXTENDERS 

GLUE WASH WATER 

RECYCLE 

AIR 

EMISSIONS 

TRIM AND SANDER DUST 

UNUSABLE 

VENEER AND 

TRIMMINGS 

BARK 

SOLID WASTE IS BURNED IN BOILER, CHIPPED FOR REFUSE, OR SOLD 

GLUE 

LEGEND 

Source: Estimating Chemical Releases from Presswood and Laminated Wood Products Manufacturing, U.S. EPA, Office of 

Pesticides and Toxic Substances, March 1988. 

Note: Many veneer and plywood plants are dry. 

SIC Code 24 20 September 1995 
Sector Notebook Project Lumber and Wood Products 

Reconstituted Wood Products 

Reconstituted wood products, such as particleboard (PB), medium 

density fiberboard (MDF), hardboard (HB), and oriented strand board 

(OSB), is composed of furnish, or raw wood, that is combined with resins 

and other additives and formed into a mat, which is then pressed into a 

board. The manufacturing processes of these boards differ, as do the raw 

materials used. For example, the furnish (raw materials) used for 

particleboard consists of finely ground wood particles of various sizes, 

while OSB is manufactured using specially-prepared strands of wood. In 

general, the manufacturing processes involve wood size reduction 

followed by drying (except for wet process boards), adhesive application, 

pressing at elevated temperatures. Because these products are based on 

use of all parts of the sawn log, very little solid waste is generated. 

Instead, air emissions from dryers and presses tend to be the principal 

environmental concern stemming from the production of these products. 

Exhibit 8 compares the process flows for some reconstituted wood 

product manufacturing processes. 

Particleboard (PB) 

Particleboard is a panel product made from wood particles of various 

sizes that are bonded together with a synthetic resin such as ureaformaldehyde (UF). The raw materials, or "furnish," that are used to 

manufacture PB can be either green or dry wood residues. Green 

residues include planer shavings from green lumber, and green sawdust. 

Dry process residues include shavings from planing kiln-dried lumber, 

sawdust, sanderdust and plywood trim. The wood residues are ground 

into particles of varying sizes using flakers, mechanical refiners, and 

hammermills. The material may be screened prior to refining. 

The furnish is dried to a low moisture content (two to six percent) to 

allow for moisture that will be gained by the adding of resins and other 

additives during "blending." Furnishes are generally no warmer than 

100•F when blended to avoid precuring and the drying out of the resin. 

Most dryers currently in operation in PB and other reconstituted wood 

panel manufacturing plants use large volumes of air to convey material of 

varied size through one or more passes within the dryer. Rotating drum 

dryers requiring one to three passes of the furnish are most common. The 

use of triple-pass dryers predominates in the United States (see Exhibit 9). 

Dryer temperatures may be as high as 1100 - 1200•F with a wet furnish. 

However, dry planer shavings require that dryer temperatures be no 

higher than 500•F because the ignition point 

September 1995 21 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 8

Reconstituted Wood Panel Process Flow

WOOD REDUCTION 

PB 

Wood residues are 

ground into fine particles 

of varying sizes 

OSB 

Logs are debarked 

and cut into strands 

Fiberboards 

Wood residues are heated in a 

steam cooker and mechanically 

separated into fibers 

DRYER 

DRY 

FORMING 

PRESSING 

WET 

FORMING 

(Binder Applied) 

OSB 

Logs are debarked 

and cut into strands 

MDF Hardboard 

Dry 

Hardboard 

Wet & 

Wet/Dry 

Hardboard 

Wet 

Hardboard 

Wet/Dry 

OVEN 

PRESSING 

Hardboard 

Wet/Dry 

BINDER APPLICATION 

(for MDF) 

BINDER APPLICATION 

(for OSB and PB) 

Source: Characterization of Manufacturing Processes, Emissions, and Pollution Prevention - Options 

for the Composite Wood Industry; Martin and Northeim, Research Triangle Institute Center for 

Environmental Analysis, 1995. 

SIC Code 24 22 September 1995 
Sector Notebook Project Lumber and Wood Products 

of dry wood is 446•F. Dry material is the predominant furnish in 

particleboard. Many dryers are directly heated by dry fuel suspension 

burners. Others are heated by burning oil or natural gas. 

Exhibit 9 

Schematic of a Triple Pass Drum Dryer 

MATERIAL 

INLET MATERIAL 

EXIT 

Hot 

Gases 

From 

Burner 

Source: Characterization of Manufacturing Processes, Emissions, and Pollution Prevention - Options 

for the Composite Wood Industry; Martin and Northeim, Research Triangle Institute Center for 

Environmental Analysis, 1995. 

Direct-fired rotary drum dryers release emissions such as wood dust, 

combustion products, fly ash, and organic compounds evaporated from 

the extractable portion of the wood. Steam-heated and natural gas-filled 

dryers will have no fly ash. 

Air classifiers, which separate particles by surface area and weight, may 

be used alone or in conjunction with screening equipment. Air classifiers 

perform best if the feed is limited to particles with uniform widths and 

lengths. The classifier can then efficiently separate particles of different 

thicknesses due to the weight difference among particles of 

approximately equal surface area. Undesired material is usually used as 

fuel for the dryer burner. The screened particles are stored in dry bins 

until they are conveyed to the blender. Air classifiers have limited use in 

the industry. Screening systems are typically used to separate fine from 

coarse material. 

The furnish is then blended with a synthetic adhesives, wax, and other 

additives distributed via spray nozzles, simple tubes, or atomizers. Resin 

may be added as received (usually an aqueous solution); mixed with 

water, wax emulsion, catalyst, or other additives. Waxes are added to 

impart water repellency and dimensional stability to the boards upon 

wetting. 

Particles for PB are mixed with the additive in short retention time 

blenders in through which the furnish passes in seconds. The blenders 

September 1995 23 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

consist of a small horizontal drum with high-speed, high shear impellers 

and glue injection tubes. As the furnish enters the drum, resin is injected, 

and the impellers hurl the furnish at high speeds to mix it with the resin. 

The furnish and resin mixture is then formed into mats using a dry 

process. This procedure uses air or a mechanical system to distribute the 

furnish onto a moving caul (tray), belt, or screen. Particleboard mats are 

often formed of layers of different sized particles, with the larger particles 

in the core, and the finer particles on the outside of the board. 

The mats are hot pressed to increase their density and to cure the resin. 

Most plants use multiopening platen presses, which typically have 14 to 

18 openings (see Exhibit 10). The last ten years has seen the introduction 

of the continuous press. Though more popular in Europe, the continuous 

press is currently being used in two PB plants in the United States. Steam 

generated by a boiler that burns plant residuals runs through a platen 

passageway to provide the heat in most hot presses. Hot oil and hot 

water can also be used to heat the platens. 

Primary finishing steps for all reconstituted wood panels include cooling 

or hot stacking, grading, trimming/cutting, and sanding. Cooling is 

important for UF-resin-cured boards since the resin degrades at high 

temperatures after curing. Boards bonded using PF resins may be hotstacked to provide additional curing time. Secondary finishing steps 

include filling, painting, laminating, and edge finishing. The vast 

majority of reconstituted panel manufacturers do not apply secondary 

finishes to their panels; panels are finished primarily by end-users such as 

cabinet and furniture manufacturers. Panels are also finished by 

laminators who then sell the finished panels to furniture and cabinet 

manufacturers. 

SIC Code 24 24 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 10 

Schematic of a Multi-Opening Board Press 

Source: Characterization of Manufacturing Processes, Emissions, and Pollution Prevention - Options 

for the Composite Wood Industry; Martin and Northeim, Research Triangle Institute Center for 

Environmental Analysis, 1995. 

September 1995 25 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Medium Density Fiberboard (MDF) 

The uses for this type of composite wood product are similar to those of 

PB. The furnish used to manufacture MDF consists of the same type of 

green or dry wood residues used to manufacture PB and hardboard. 

Fibers and fiber bundels are generated by first steam-heating the wood, 

then passing it through a refiner. During this step the wood changes both 

chemically and physically; becoming less susceptible to the influences of 

moisture and less brittle as the lignin in the wood softens. This semiplastic wood is then "rubbed" apart into fibers and fiber bundles in a 

refiner instead of being mechanically "broken" apart as in the PB 

manufacturing process. 

The furnish is dried to a very low moisture content to allow for moisture 

to be gained by the addition of resins and other additives. Most MDF 

furnish is dried in tube dryers. 

The blending process for MDF differs from that of PB in that it typically 

occurs before drying. After refining, the fibers are discharged through a 

valve known as the blowvalve into the blowline, a larger continuous 

chamber where the UF resins are mixed with the wood fiber. In the 

blowline, the fibers are sprayed with a resin which is injected from a line 

located either immediately after the blowvalve or anywhere along the 

blowline. Material is dried to an acceptable moisture content in a flash 

tube dryer at low temperatures after the blowline. If the blending is done 

mechanically, as in PB, it is done after the flash tube dryer. 

MDF is formed using a dry process which uses air to distribute the 

furnish in a random orientation onto a moving caul (tray), belt, or screen. 

The mats are then pressed using a multi-opening platen press or a 

continuous press is currently used in three MDF plants in the United 

States. The boards are then cooled and finished like other reconstituted 

wood panels. 

Hardboard 

Hardboard is a higher-density version of MDF. It is typically used for 

siding, furniture drawer bottoms, dust stops, sliding doors, and cabinet 

doors and tops. There are three types of hardboard: wet, wet/dry, and 

dry process hardboard, each classified by their manufacturing processes. 

The furnish used to manufacture hardboard consists of the same green or 

dry process wood residues used to manufacture PB and MDF. The 

cooked semi-plastic furnish is "rubbed" apart into fiber bundles as in the 

SIC Code 24 26 September 1995 
Sector Notebook Project Lumber and Wood Products 

MDF process. The fibers are all the same size, therefore, they need no 

screening. 

In the manufacture of wet, and wet/dry process hardboard, the furnish is 

not dried because the forming process uses water. Wet and wet/dry 

process hardboard mats are formed using a wet process in which fibers 

are mixed with water and Phenol Formaldehyde adhesive and then 

metered onto a wire screen. Water is drained away with the aid of 

suction applied to the underside of the wire. The fiber mat, along with 

the supporting wire, is moved to a prepress where excess water is 

squeezed out. Wet/dry process hardboard is dried in an oven before 

being hot pressed. 

In the manufacture of dry process hardboard, the furnish is dried using 

dryers typical of the reconstituted wood panel industry. As with MDF, 

the hardboard fibers are discharged through a blowvalve into a blowline 

after refining. Dry process hardboard mats are formed using a process 

similar to that of MDF and PB in which air is used to distribute the 

furnish in a random orientation onto a moving caul (tray), belt, or screen. 

All reconstituted wood panels are hot pressed to increase their density 

and to cure the resin. 

Oriented Strandboard 

The furnish used to manufacture OSB is specially flaked from 

roundwood. Logs entering OSB plants may be either tree length or cut to 

100 inch lengths by a slasher saw. The logs are then debarked and sent to 

a strander which slices them into strands approximately 0.028 inch thick. 

The strands are then conveyed to a storage bin to await processing 

through the dryers. (Note: Some older mills cut the logs into 33 inch 

blocks before sending them to the strander.) 

The strands are dried to a low moisture content to allow for moisture 

gained by adding resins and other additives. The strands are then 

blended with additives in long retention time blenders in which the 

furnish passes through in several minutes. The blenders are very large 

rotating drums (several feet in diameter and many feet in length) that are 

tilted on their axes. As the strands are fed into the drums, they are 

sprayed with either PF or MDI (Methylenediphenyl diisocyanate) resin 

and either liquid or emulsified paraffin wax. The tumbling action of the 

strands through the drums allows the strands to mix thoroughly with the 

resin and wax. 

September 1995 27 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

OSB is formed by a dry process, which uses air to distribute the furnish. 

OSB is produced by deliberate mechanical lining-up of the strands. In the 

mechanical orientation processes, mats are produced by dropping long 

slender flakes between parallel plates or disks onto a moving caul (tray), 

belt, or screen. The boards are then hot pressed and finished. 

Engineered Lumber 

Several composite wood products, intended as substitutes for lumber as 

well as other structural materials, are now on the market. Parallel strand 

lumber, made from long strands of veneer, is extruded with PF resin into 

various cross sections and widths. Parallel laminated veneer, or 

laminated veneer lumber (LVL), is constructed of veneers that are bonded 

together with phenol-formaldehyde (PF) adhesive resin to form a 

laminate. The veneers are layered with the wood grain along the long 

axis of the beam. Laminated veneer lumber is manufactured to typical 

lumber sizes (2 x 4, 2 x 6, etc.). The length of the beams that can be 

manufactured is varied using end joints or finger joints. Another 

application of LVL is in the construction of wood "I" joists (a small beam 

that resembles the letter "I"). LVL is used to construct the top and bottom 

(flanges) of the joist and OSB or plywood is used to construct the center 

(web). 

Glulam beams are also emerging as a substitute for lumber. Glulam is 

short for glued-laminated structural timber – large beams fabricated by 

bonding layers of specially-selected lumber with Resorcinol or 

Resorcinol/PF adhesives and timber. End and edge jointing permit 

production of longer and wider structural wood members than are 

available naturally. Glulam timbers are used with structural wood panels 

for many types of heavy timber construction. 

Most of the engineered lumber products are used as substitutes for 

structural softwood lumber of large sizes and in applications where 

uniform strength is essential. I-beams, however, are finding wide 

application, with extensive use as floor joists and beams for various 

structures. There are several advantages of composite lumber when 

compared with sawn softwood lumber. First, these products allow 

production of large sizes of lumber from small, low-grade logs. 

Normally, relatively large and high-grade sawlogs are needed for 

production of lumber of this size. Second, composite lumber compares 

advantageously to solid sawn lumber in terms of both uniformity of 

quality and straightness. While the quality of lumber is determined to a 

great extent by the raw material, the quality of the reconstituted product 

SIC Code 24 28 September 1995 
Sector Notebook Project Lumber and Wood Products 

is dependent upon the manufacturing process. It is likely, however, that 

use of composite lumber will increase in the future. 

Wood Preserving 

Wood is treated with preservatives to protect it from mechanical, 

physical, and chemical influences. Preserved wood is used primarily in 

the construction, railroad, and utilities industries to prevent rotting when 

wood is exposed to damp soil, standing water, or rain, and as protection 

against termites and marine borers. The most common preservatives 

include water-borne inorganics like chromated copper arsenate (CCA) 

and ammoniacal copper zinc arsenate (ACZA), and oil-borne organics like 

pentachlorophenol (PCP) and creosote. Generally, water-borne inorganic 

solutions constitute approximately 78 percent of all preservatives used, 

while oil-borne creosote and PCP comprise 15 percent and 6 percent, 

respectively. 

Creosote, PCP, and inorganic wood preservatives are all applied using 

similar processes. More than 90 percent of the wood preservation in the 

U.S. is performed using pressure treatment processes. Exhibit 10 

illustrates a two-cylinder pressure treatment process for CCA. A limited 

quantity of wood is preserved using non-pressure treatment processes in 

which the preservative is allowed to diffuse into the wood. This process 

is used with some oil-borne preservatives, but not with waterborne 

inorganics. 

The penetration required to adequately preserve wood can be achieved 

only if the wood has been conditioned properly; that is, if the moisture 

content of the freshly-cut wood is reduced to a point where the 

preservative can penetrate and be retained by the wood. Wood is usually 

conditioned in the open air or conditioned in the cylinder (retort) in 

which the pressure treatment is performed. The sawn lumber is 

sometimes incised to increase preservative penetration. Open air drying 

is typically used to prepare large stock for treatment with oil-borne 

preservatives. Other methods for conditioning wood prior to treatment 

with oil-borne preservatives include steaming, heating, and vapor drying. 

Kiln drying is used primarily for water-borne treatment. Conditioning is 

a major source of wastewater in the wood preserving industry. 

After the moisture content of the wood has been reduced, the wood is 

preserved using either non-pressure or pressure methods. Non-pressure 

processes include brushing, spraying, dipping, soaking, and thermal 

processes. These processes involve the repeated use of preservative in a 

treatment tank with fresh preservative solution added to replace 

September 1995 29 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

consumptive loss. The continual reuse of preservative leads to the 

accumulation of wood chips, sand, stones, and other debris contaminated 

with various hazardous constituents in the bottom of the treating tanks. 

This contaminated debris is a major source of process waste for nonpressure processes. 

SIC Code 24 30 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 11

Example Flow Diagram For a Two-Cylinder CCA Pressure-Treating Facility

Preservative 

Solution 

50% CCA 

Concentrate 

Storage Tank 

Wood 

Stock 

CCA 

Retort 

CCA 

Retort 

CCA Work 

Tank 

CCA Work 

Tank 

Effluent 

Water 

Tank II 

Freshly Treated Wood Preservative 

Drip Recovery 

PAD 

Effluent 

Water 

Tank I 

1 1 

To Retorts 

CCA 

Treated 

Wood 

1 1 

F 

In-Process 

Preservative 

Drip Recovery 

Preservative 

Solution 

1 -

F -

Solid Waste Managed in Containers (including Sawdust, Dirt, and Road Grime) for Subsequent Off-Site Disposal 

Filter 

Source: Title III, Section 313 Release Reporting Guidance; Office of Pesticides and Toxic Substances; March 1983. 

There are two basic types of pressure treatment processes, distinguished 

by the sequence in which vacuum and pressure are applied. These are 

"empty-cell" and "full-cell" or "modified full cell" processes. The terms 

"empty" and "full" are measures of the level of preservative retained by 

the wood cells. 

"Empty-cell" processes obtain relatively deep penetration with limited 

absorption of preservative. In the Reuping empty-cell process, air 

pressure is applied to the wood as preservative is pumped into the 

treating cylinder. Once the desired level of retention has been achieved, 

the unused preservative is drained off and the excess preservative is 

vacuum pumped away from the wood. The process is the same in the 

Lowry empty-cell process, except no initial pressure is applied. In both 

processes, air compressed in the wood drives out part of the preservative 

absorbed during the pressure period when pressure is released. 

September 1995 31 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

The second method, know as the "full-cell" (Bethel) process, results in 

higher retention of preservative but limited penetration compared to the 

empty-cell process. The full-cell or modified full cell procedures are used 

with both oil- and water-borne preservatives. A vacuum is created in the 

treating cylinder and preservative is pumped in without breaking the 

vacuum. Once full, hydrostatic or pneumatic pressure is applied until the 

wood will retain no more preservative. A final vacuum may then be 

applied to remove excess preservative, which is returned to the work tank 

for reuse. The treated wood is removed from the cylinder and placed on 

a drip pad where it remains until dripping has ceased (see Exhibit 12). 

Preservative solution, washdown water, and rainwater are collected on 

the drip pad and maintained in the process. At waterborne plants, these 

materials are transferred to a dilution water tank where they are blended 

with additional concentrate to make fresh treating solution. At oil-borne 

plants, these materials are processed to recover preservative and usable 

process water. Excess waste water is treated either on-site in a 

wastewater treatment unit or off-site at a publicly owned treatment 

works. 

Exhibit 12

Drip Pad with Liner

Rail System for Wood Treating 

Cylinder Trams 

Drainage 

Liner 

Sand 

Granular Fill 

Concrete 

Source: U.S. EPA. 

SIC Code 24 32 September 1995 
Sector Notebook Project Lumber and Wood Products 

III.B. Raw Material Inputs and Pollution Outputs 

Exhibit 13 provides an overview of the material inputs and pollution 

outputs for different processes in the lumber and wood products 

industry. 

Logging 

With the exception of concerns for species and ecosystem preservation, 

harvesting practices have minimal environmental impacts. Harvesting 

practices often cause discharges of materials into surrounding waters, 

threatening water quality standards. The Federal Water Protection 

Control Act regulates these discharges. In addition, road construction for 

access to timber areas is of concern, due to impacts on surrounding 

ecosystems. 

September 1995 33 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 13 

Process Materials Inputs and Pollution Outputs 

Process Material Input Air Emissions Process Waste Other Waste 

Logging Trees, diesel, gasoline PM-10, VOCs, CO, 

NOx 

Not applicable Waste wood 

particles 

Sawing Wood logs, diesel, gasoline PM-10, VOCs, CO, 

NOx 

Not applicable Waste wood 

particles 

Surface 

Protection 

Wood, 3-Iodo-2-Propynyl 

Butyl Carbamate (IPBC), 

Didecyl Dimethyl 

Ammonium Chloride 

(DDAC) 

IPBC, DDAC, ethyl 

alcohol, petroleum 

naphtha 

Dripped 

formulation mixed 

with rainwater and 

facility washdown 

water 

Sawdust, 

wood chips, 

sand, dirt, 

stones, tar, 

emulsified or 

polymerized 

oils 

Plywood and 

Veneer 

Veneer, phenolformaldehyde resins, ureaformaldehyde resins, 

melamine-formaldehyde 

resins, sodium hydroxide, 

ammonium sulfate, acids, 

ammonia 

PM-10, VOCs, CO, 

CO2, NOx, 

formaldehyde, 

phenol, wood dust, 

condensable 

hydrocarbons, 

terpenes, methanol, 

acetic acid, ethanol, 

furfural 

Not applicable Waste wood 

particles, 

adhesive 

residues 

Reconstituted 

Wood 

Products 

Wood particles, strands, 

fiber, same resins as 

plywood and veneer, 

methylenediphenyl 

diisocyanate resins 

PM-10, VOCs, CO, 

CO2, NOx, 

formaldehyde, 

phenol, wood dust, 

condensable 

hydrocarbons, 

terpenes, methanol, 

acetic acid, ethanol, 

furfural 

Not applicable Waste wood 

particles, 

adhesive 

residues 

Wood 

Preserving 

Wood, pentachlorophenol, 

creosote, borates, 

ammonium compounds, 

inorganic formulations of 

chromium, copper, and 

arsenic, carrier oils 

Pentachlorophenol, 

polycyclic organics, 

creosote, ammonia, 

boiler emissions, airborne arsenics, 

VOCs 

Dripped 

formulation mixed 

with rainwater and 

facility washdown 

water, kiln 

condensate, contact 

cooling water 

Bottom 

sediment 

sludges, 

process 

residuals 

Sawn Lumber 

Most of the residual wood from sawn lumber production is reused as 

mulch, pulp, and furnish for some types of reconstituted wood panels; 

some is burned to produce steam or electricity. Studies cited by the 

Western Wood Products Association indicate that approximately 70 

percent of a sawn log is utilized for lumber and other parts are used for 

SIC Code 24 34 September 1995 
Sector Notebook Project Lumber and Wood Products 

co-products. Some of the small residuals are gathered with pneumatic 

systems for combination with larger amounts destined for use in other 

products. While there is virtually no waste from the manufacturing 

process because all parts of the log are used for one product or another, 

wood residuals are high in organic matter and can threaten aquifers if 

improperly handled. 

A major emission of concern from wood boilers is particulate matter 

(PM), although other pollutants, particularly CO and organic compounds, 

may be emitted in significant quantities under poor operating conditions. 

Boilers that burn wood waste produce: fly ash, carbon monoxide, and 

volatile organic compounds (VOCs). New boilers must meet new source 

performance standards (NSPS) for air pollutants. In addition, mills are 

potential sources of toxic manganese air emissions. 

Two types of primary waste streams are typically generated during the 

surface protection phase of sawn lumber production operations: process 

residuals and drippage. Secondary waste streams include spent 

formulations and wastewaters. 

Typical process residuals from surface protection are tank sludges that 

accumulate in the dip tank and/or mix tank as a result of continuous 

reuse of the protectant. Some plants use spray systems that generate a 

sludge when recovered formulation is filtered. Periodically, the 

accumulated sludge must be removed, and is typically placed on sawdust 

or wood chip piles on-site. The ultimate destination of the sludge is 

dependent upon the management of the sawdust piles. Plants have 

reported burning sawdust on-site or shipping it off-site for use as boiler 

feed for energy recovery. Depending upon the particle size, some wood 

chips may be shipped to a pulp or paper mill. 

Some plants generate little or no tank sludge as a result of certain process 

variations. Dip tank operations sometimes utilize an internal circulation 

system to enhance mixing and promote penetration into the packed 

bundles. The agitation does not allow any particulates to settle, and when 

the bundles are removed, some of the suspended solids are also removed. 

Green-chain operations sometimes use a system of rollers that are 

partially submerged into the dip tank. These rollers force the pieces of 

lumber under the surface of the formulation to ensure thorough coverage 

of the exposed surfaces. Forcing the lumber deeper into the tank 

physically drags the lumber through any sludge that has settled in the 

tank and this sludge leaves the tank with the treated lumber. 

September 1995 35 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Another wastestream results from the excess formulation drippage from 

freshly surface protected lumber. In the absence of a drip pad, excess 

drippage can fall on the ground when the wood is transported from the 

dip tank or green chain to stacking and packaging areas. Spray 

operations tend to result in less excess formulation on the wood than 

either the dipping or green-chain operations. Some plants utilize simple 

recovery systems to minimize the loss of formulation. For example, pack 

dip operations hold the wood over the dip tank at an angle to collect 

excess formulation prior to transfer to storage. Green chain and spray 

operations may utilize a collection pan under the conveyor to collect 

formulation as the freshly treated lumber runs along the green chain. 

Panel Products 

In mills where chips or other furnish is generated on-site, operations such 

as debarking, sanding, chipping, grinding, and fiber separation generate 

PM emissions in the form of sawdust and wood particulate matter. The 

following discussion of pollution outputs from panel production is not 

divided along product lines. Instead, due to similarities in manufacturing 

process, this section describes pollution outputs during the drying and 

pressing stages, where most emissions occur. 

Dryers 

Organic aerosols and gaseous organic compounds, along with a small 

amount of wood fiber are found in the emissions from veneer 

impingement dryers. A mixture of organic compounds is driven from the 

green wood veneer as its water content is converted to steam in the 

drying process. Aerosols begin to form as the gaseous emissions are 

cooled below 302•F. These aerosols form visible emissions called blue 

haze. 

Emissions from the rotating drum wood chip dryers used in reconstituted 

wood panel plants are composed of wood dust, condensable 

hydrocarbons, fly ash, organic compounds evaporated from the 

extractable portion of the wood, and may include products of combustion 

such as CO, CO2, and NOx if direct-fired units are used. The organic 

portion of industry emissions includes terpenes, resin and fatty acids, and 

combustion and pyrolysis products such as methanol, acetic acid, ethanol, 

formaldehyde, and furfural. The condensable hydrocarbons and a 

portion of the VOCs leave the dryer stack as vapor but condense at 

normal atmospheric temperatures to form liquid particles that create the 

blue haze. Both the VOCs and the liquid organic mist are combustion 

SIC Code 24 36 September 1995 
Sector Notebook Project Lumber and Wood Products 

products and compounds evaporated from the wood. Quantities emitted 

are dependent on wood species, dryer temperature, and fuel used. 

One significant cause of blue haze is overloading a dryer by attempting to 

remove too much moisture within a given time. Overloading results in 

the introduction of green material to a high-temperature flame or gas 

stream causing a thermal shock that results in a rapid and excessive 

volatilizing of hydrocarbons that condense upon release to ambient air, 

causing the characteristic blue haze. 

Another factor affecting the composition of the effluent from rotary drum 

dryers is inlet dryer temperatures. A study conducted in 1986 by The 

National Council of the Paper Industry for Air and Stream Improvement 

(NCASI) with data from five different mills using rotary drum dryers 

concluded that at inlet gas temperatures greater than 600•F, the emission 

rate of the total condensable portion of total gaseous nonmethane organics 

(TGNMO) increased as a function of temperature. The report concluded 

that the concentration of formaldehyde in the dryer exhaust was also 

directly related to dryer inlet temperature. 

The type of wood species burned also affects the composition of the 

effluent from rotary drum dryers. A second NCASI study concluded that 

high TGNMO emission rates from the dryers occurred when the wood 

species processed had high turpentine contents, such as Southern Pine. In 

a separate study on formaldehyde emissions, NCASI showed that dryers 

processing hardwood or a mixture of hardwood and softwood species 

had a moderate to dramatic increase in formaldehyde emissions at dryer 

inlet gas temperatures greater than 800•F, but dryers processing only 

softwood species had only a slight increase in formaldehyde emissions 

with increasing temperatures. 

Presses 

Emissions from board presses are dependent upon the type of resin used 

to bind the wood furnish together. Emissions from hot presses consist 

primarily of condensable organics. When the press opens, vapors that 

may include resin ingredients such as formaldehyde, phenol, MDI, and 

other organic compounds are released to the atmosphere through vents in 

the roof above the press. Formaldehyde emitted through press vents 

during pressing and board cooling operations is dependent upon the 

amount of excess formaldehyde in the resin as well as press temperature 

and cycle time. 

September 1995 37 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Mole ratios are used to measure the number of moles of one compound to 

another in an adhesive. For example, the F:U (formaldehyde to urea) 

mole ratio measures the number of moles of formaldehyde to the number 

of moles of urea in the principal adhesive used for PB and MDF. The 

nature of the product and the process dictates the mole ratio of resin used. 

The ratio directly impacts the ultimate strength the resin will produce in 

the board, i.e., certain products require higher mole ratio resins to attain 

an adequate level of bond strength. The higher the mole ratio, the higher 

the board emissions of formaldehyde. Thus lowering the F:U mole ratio 

is one way of lowering press and board emissions of formaldehyde. 

However, mole ratio is only one of several variables that can effect 

formaldehyde emissions. Other variables include application rates, 

process rates, and the nature of the specific resin formations. 

Higher press temperatures generally result in higher formaldehyde 

emissions. In an NCASI study, emissions of formaldehyde and phenol 

from PF resins (used mainly for OSB) and structural plywood were not 

found to be related to any operating procedures, but were affected by 

different resin compositions. The types of resins used can effect the 

amount of emissions. There was little information on emissions from the 

curing of MDI resins (used for OSB along with PF resins). 

Wood Preserving 

The chemicals used in the wood preserving process and the drip pads 

used to collect preservative drippage after treatment of wood have been 

the subject of considerable regulatory action. EPA has issued final 

regulations regarding wood preserving wastewater, process residuals, 

preservative drippage, and spent preservatives from wood preserving 

processes at facilities that use chlorophenolic formulations, creosote 

formulations, and inorganic preservatives containing arsenic or 

chromium. 

There are six EPA-classified hazardous wastes from wood preserving 

operations. These are: U051, discarded unused creosote, F027, discarded 

unused pentachlorophenol-formulation; K001, bottom sediment sludge 

from the treatment of wastewaters from wood preserving processes that 

use creosote or PCP; F032, wastewaters, process residuals, preservative 

drippage, and spent formulations from wood preserving processes 

generated at plants that currently use or have previously used 

chlorophenolic formulations; F034, wastewaters, process residuals, 

preservative drippage, and spent formulations from wood preserving 

processes generated at plants that use creosote formulations; and F035, 

wastewaters, process residuals, preservative drippage, and spent 

SIC Code 24 38 September 1995 
Sector Notebook Project Lumber and Wood Products 

formulations from wood preserving processes generated at plants that use 

inorganic preservatives containing arsenic or chromium. 

Drips and spills during the oilborne preservative process may occur 

during chemical delivery, chemical storage and mixing, freshly-treated 

wood storage on bare ground (if RCRA guidelines are not followed), and 

dry-treated wood storage on ground. Aerosols and vapors may be 

released to ambient air during chemical storage and mixing, solution 

storage, and during pressure treatment (once the cylinder is opened). 

Sludges result if filters are used prior to solution reuse from wastewater 

treatment, and from the collection sumps at the facility. 

During the inorganic treatment process, additional vapors such as arsenic, 

may be released to ambient air during the pressure treating process, such 

as from the process tank or work vent during the initial vacuum stage, the 

flooding via vacuum, pressure relief and blow back, and the final 

vacuum. Aerosols and vapor may also be released from the cylinder door 

area during pressure treating and door opening. 

Wood preserving facilities generate wastewater during the conditioning 

of the wood prior to its treatment and as a result of the condensation 

removed from the treatment cylinder. Rainwater, spills collected from the 

area around the treatment cylinder, and drip pad wash down water also 

contribute to wastewater volume. Typical air emissions sources are 

volatilization of organic chemicals during wastewater evaporation, vapors 

released from the treating cylinder during unloading and charging 

operations, and emissions from the vacuum vent during the treating 

cycle. 

After both pressure and non-pressure treatment, some unabsorbed 

preservative formulation adheres to the treated wood surface. 

Eventually, this liquid drips from the wood or is washed off by 

precipitation. If the wood has been pressure treated, excess preservative 

will also exude slowly from the wood as it gradually returns to 

atmospheric pressure. This is known as "kickback." Current regulations 

specify that all wood must be drip-free prior to transfer from a drip pad 

to a storage yard. Also, storage-yard drippage resulting from "kickback" 

must be cleaned up within 72 hours of the occurrence. Preservative 

formulation may continue to exude from pressure and non-pressure 

treated wood for long periods, even after the wood is shipped off-site and 

installed for its intended end use. (See Exhibit 11 for schematic of wood 

preserving process and waste generation) 

September 1995 39 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

III.C. Management of Chemicals in Wastestream 

The Pollution Prevention Act of 1990 (EPA) requires facilities to report 

information about the management of TRI chemicals in waste and efforts 

made to eliminate or reduce those quantities. These data have been 

collected annually in Section 8 of the TRI reporting Form R. beginning 

with the 1991 reporting year. The data summarized below cover the years 

1992-1995 and is meant to provide a basic understanding of the quantities 

of waste handled by the industry, the methods typically used to manage 

this waste, and recent trends in these methods. TRI waste management 

data can be used to assess trends in source reduction within individual 

industries and facilities, and for specific TRI chemicals. This information 

could then be used as a tool in identifying opportunities for pollution 

prevention and compliance assistance activities. 

While the quantities reported for 1992 and 1993 are estimates of quantities 

already managed, the quantities reported for 1994 and 1995 are 

projections only. The EPA requires these projections to encourage 

facilities to consider future waste generation and source reduction of 

those quantities as well as movement up the waste management 

hierarchy. Future-year estimates are not commitments that facilities 

reporting under TRI are required to meet. 

Exhibit 14 shows that the lumber and wood products industry managed 

about 69 million pounds of production-related waste (total quantity of 

TRI chemicals in the waste from routine production operations) in 1993 

(column B). Column C reveals that of this production-related waste, 17 

percent was either transferred off-site or released to the environment. 

Column C is calculated by dividing the total TRI transfers and releases by 

the total quantity of production-related waste. In other words, about 84 

percent of the industry's TRI wastes were managed on-site through 

recycling, energy recovery, or treatment as shown in columns D, E and F, 

respectively. The majority of waste that is released or transferred off-site 

can be divided into portions that are recycled off-site, recovered for 

energy off-site, or treated off-site as shown in columns G, H, and I, 

respectively. The remaining portion of the production-related wastes 

(13.2 percent), shown in column J, is either released to the environment 

through direct discharges to air, land, water, and underground injection, 

or it is disposed off-site. 

From the yearly data presented below it is apparent that the portion of 

TRI wastes reported as recycled on-site has increased and the portions 

treated or managed through energy recovery on-site have decreased 

between 1992 and 1995 (projected). 

SIC Code 24 40 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 14

Source Reduction and Recycling Activity for SIC 24

A B C D E F G J 

Production 

Related 

Waste 

% Reported 

as Released On-Site Off-Site 

Remaining 

Releases 

Year 

Volume 

(106lbs.)* 

and 

Transferred 

% 

Recycled 

% Energy 

Recovery 

% 

Treated 

% 

Recycled 

% Energy 

Recovery 

% 

Treated 

and 

Disposal 

1992 33 45% 55.17% 0.10% 11.02% 0.06% 1.84% 2.12% 29.69% 

1993 69 17% 78.30% 0.05% 5.90% 0.07% 1.36% 1.09% 13.23% 

1994 66 — 79.59% 0.07% 5.32% 0.08% 0.86% 0.59% 13.50% 

1995 63 — 79.15% 0.03% 5.63% 0.09% 0.74% 0.62% 13.72% 

H I 

September 1995 41 SIC Code 24
Lumber and Wood Products Sector Notebook Project 

IV. CHEMICAL RELEASE AND TRANSFER PROFILE 

This section is designed to provide background information on the 

pollutant releases that are reported by this industry. The best source of 

comparative pollutant release information is the Toxic Release Inventory 

System (TRI). Pursuant to the Emergency Planning and Community 

Right-to-Know Act, TRI includes self-reported facility release and transfer 

data for over 600 toxic chemicals. Facilities within SIC Codes 20-39 

(manufacturing industries) that have more than 10 employees, and that 

are above weight-based reporting thresholds are required to report TRI 

on-site releases and off-site transfers. The information presented within 

the sector notebooks is derived from the most recently available (1993) 

TRI reporting year (which then included 316 chemicals), and focuses 

primarily on the on-site releases reported by each sector. Because TRI 

requires consistent reporting regardless of sector, it is an excellent tool for 

drawing comparisons across industries. 

Although this sector notebook does not present historical information 

regarding TRI chemical releases over time, please note that in general, 

toxic chemical releases have been declining. In fact, according to the 1993 

Toxic Release Inventory Data Book, reported releases dropped by 42.7% 

between 1988 and 1993. Although on-site releases have decreased, the 

total amount of reported toxic waste has not declined because the amount 

of toxic chemicals transferred off-site has increased. Transfers have 

increased from 3.7 billion pounds in 1991 to 4.7 billion pounds in 1993. 

Better management practices have led to increases in off-site transfers of 

toxic chemicals for recycling. More detailed information can be obtained 

from EPA's annual Toxics Release Inventory Public Data Release book 

(which is available through the EPCRA Hotline at 1-800-535-0202), or 

directly from the Toxic Release Inventory System database (for user 

support call 202-260-1531). 

Wherever possible, the sector notebooks present TRI data as the primary 

indicator of chemical release within each industrial category. TRI data 

provide the type, amount, and media receptor of each chemical released 

or transferred. When other sources of pollutant release data have been 

obtained, these data have been included to augment the TRI information. 

TRI Data Limitations 

The reader should keep in mind the following limitations regarding TRI 

data. Within some sectors, the majority of facilities are not subject to TRI 

reporting because they are not considered manufacturing industries, or 

because they are below TRI reporting thresholds. Examples are the 

SIC Code 24 42 September 1995 
-- 

Sector Notebook Project Lumber and Wood Products 

mining, dry cleaning, printing, and transportation equipment cleaning 

sectors. For these sectors, release information from other sources has been 

included. 

The reader should also be aware that TRI "pounds released" data 

presented within the notebooks is not equivalent to a "risk" ranking for 

each industry. Weighting each pound of release equally does not factor in 

the relative toxicity of each chemical that is released. The Agency is in the 

process of developing an approach to assign toxicological weightings to 

each chemical released so that one can differentiate between pollutants 

with significant differences in toxicity. As a preliminary indicator of the 

environmental impact of the industry's most commonly released 

chemicals, the notebook briefly summarizes the toxicological properties of 

the top five chemicals (by weight) reported by each industry. 

Definitions Associated With Section IV Data Tables 

General Definitions 

SIC Code -- the Standard Industrial Classification (SIC) is a statistical 

classification standard used for all establishment-based Federal economic 

statistics. The SIC codes facilitate comparisons between facility and 

industry data. 

TRI Facilities are manufacturing facilities that have 10 or more fulltime employees and are above established chemical throughput 

thresholds. Manufacturing facilities are defined as facilities in Standard 

Industrial Classification primary codes 20-39. Facilities must submit 

estimates for all chemicals that are on the EPA's defined list and are above 

throughput thresholds. 

Data Table Column Heading Definitions 

The following definitions are based upon standard definitions developed 

by EPA’s Toxic Release Inventory Program. The categories below 

represent the possible pollutant destinations that can be reported. 

RELEASES -- are an on-site discharge of a toxic chemical to the 

environment. This includes emissions to the air, discharges to bodies of 

water, releases at the facility to land, as well as contained disposal into 

underground injection wells. 

Releases to Air (Point and Fugitive Air Emissions) -- Include all air 

emissions from industry activity. Point emissions occur through confined 

September 1995 43 SIC Code 24 
--

-- 

Lumber and Wood Products Sector Notebook Project 

air streams as found in stacks, ducts, or pipes. Fugitive emissions include 

losses from equipment leaks, or evaporative losses from impoundments, 

spills, or leaks. 

Releases to Water (Surface Water Discharges) - encompass any releases 

going directly to streams, rivers, lakes, oceans, or other bodies of water. 

Any estimates for stormwater runoff and non-point losses must also be 

included. 

Releases to Land -- includes disposal of waste to on-site landfills, waste 

that is land treated or incorporated into soil, surface impoundments, 

spills, leaks, or waste piles. These activities must occur within the 

facility's boundaries for inclusion in this category. 

Underground Injection -- is a contained release of a fluid into a 

subsurface well for the purpose of waste disposal. 

TRANSFERS -- is a transfer of toxic chemicals in wastes to a facility that 

is geographically or physically separate from the facility reporting under 

TRI. The quantities reported represent a movement of the chemical away 

from the reporting facility. Except for off-site transfers for disposal, these 

quantities do not necessarily represent entry of the chemical into the 

environment. 

Transfers to POTWs are wastewaters transferred through pipes or 

sewers to a publicly owned treatments works (POTW). Treatment and 

chemical removal depend on the chemical's nature and treatment 

methods used. Chemicals not treated or destroyed by the POTW are 

generally released to surface waters or landfilled within the sludge. 

Transfers to Recycling -- are sent off-site for the purposes of regenerating 

or recovering still valuable materials. Once these chemicals have been 

recycled, they may be returned to the originating facility or sold 

commercially. 

Transfers to Energy Recovery -- are wastes combusted off-site in 

industrial furnaces for energy recovery. Treatment of a chemical by 

incineration is not considered to be energy recovery. 

Transfers to Treatment are wastes moved off-site for either 

neutralization, incineration, biological destruction, or physical separation. 

In some cases, the chemicals are not destroyed but prepared for further 

waste management. 

SIC Code 24 44 September 1995 
Sector Notebook Project Lumber and Wood Products 

Transfers to Disposal -- are wastes taken to another facility for disposal 

generally as a release to land or as an injection underground. 

IV.A. EPA Toxic Release Inventory for the Lumber and Wood Products Industry 

TRI Release amounts listed below are not associated with non-compliance 

with environmental laws. These facilities appear based on self-reported 

data submitted to the Toxic Release Inventory program. 

The TRI database contains a detailed compilation of self-reported, facilityspecific chemical releases. The top reporting facilities for this sector are 

listed below. Facilities that have reported only the SIC codes covered 

under this notebook appear in Exhibit 15. Exhibit 16 contains additional 

facilities that have reported the SIC code covered within this report, and 

one or more SIC codes that are not within the scope of this notebook. 

Therefore, Exhibit 16 includes facilities that conduct multiple operations 

— some that are under the scope of this notebook, and some that are not. 

Operations in Exhibit 16 include: 2621 - paper mills, 2611 - pulp mills, 

2631 - paper mills, and 2812 - industrial inorganic chemicals. Currently, 

the facility-level data do not allow pollutant releases to be broken apart 

by industrial process. 

Exhibits 17-19 illustrate the TRI releases and transfers for the lumber and 

wood products industry (SIC 24). For the industry as a whole, VOCs 

(such as formaldehyde, xylene, toluene, and methanol) comprise the 

largest number of TRI releases. A large amount of VOC releases, both 

fugitive and point source emissions, result in part from the extensive use 

of glues and resins in this industry. VOCs are primarily released during 

the drying and pressing phases of most wood panel product 

manufacturing processes. VOC emissions are also associated with 

solvents used to coat cabinets, decorative panels, and toys. 

September 1995 45 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 15

Top 10 TRI Releasing Lumber and Wood Product Facilities (SIC 24 only)

Rank Total TRI 

Releases in 

Pounds 

Facility Name City State 

1 638,622 Merillat Ind. Inc. Mount Jackson VA 

2 386,994 Component Concepts Inc. Thomasville NC 

3 383,100 Child Craft Inc. Co. Inc. Salem IN 

4 341,200 Afco Ind. Inc. Holland MI 

5 261,000 Decolam Inc. Orangeburg SC 

6 241,010 Abt Co. Inc. Roaring River NC 

7 234,697 Weyerhaeuser Particleboard Mill Adel GA 

8 199,000 J. H. Baxter & Co. Weed CA 

9 197,800 Georgia-Pacific Corp. Monticello 

Panelboard 

Monticello GA 

10 179,000 Northwood Panelboard Co. Solway MN 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

Exhibit 16

Top 10 TRI Releasing Lumber and Wood Product Facilities

SIC Codes Total TRI 

Releases in 

Pounds 

Facility Name City State 

2621, 2611, 

2812, 2421 

1,273,125 Weyerhaeuser Co. Longview WA 

2621, 2421, 

2436 

1,187,356 MacMillian Bloedel Inc. Pine Hill AL 

2611, 2621, 

2631, 2421 

1,059,615 Potlatch Corp. Pulp & 

Paperboard Group 

Lewiston ID 

2631, 2436, 

2499 

768,369 Weyerhaeuser Co. 

Containerboard Packaging 

Div. 

Springfield OR 

2426 638,622 Merillat Ind. Inc. Mount Jackson VA 

2493 386,994 Component Concepts Inc. Thomasville NC 

2435 383,100 Child Craft Inc. Co. Inc. Salem IN 

2493 341,200 AFCO Ind. Inc. Holland NH 

2439 261,000 Decolam, Inc. Orangeburg SC 

2493 241,010 Abt Co. Inc. Roaring River NC 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

Note: Being included on these lists does not mean that the release is associated with non-compliance with 

environmental laws. 

SIC Code 24 46 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 17

TRI Reporting Lumber and Wood Product Facilities (SIC 24) by State

State 

Number of 

Facilities State 

Number of 

Facilities 

AL 43 ND 1 

AR 18 NH 1 

AZ 2 NJ 4 

CA 19 NM 1 

CO 3 NV 1 

CT 1 NY 6 

FL 19 OH 8 

GA 35 OK 3 

HI 4 OR 24 

ID 3 PA 19 

IL 9 PR 3 

IN 11 RI 1 

KY 8 SC 20 

LA 17 SD 2 

MA 3 TN 12 

MD 6 TX 27 

ME 4 UT 1 

MI 13 VA 24 

MN 12 VT 1 

MO 6 WA 10 

MS 28 WI 18 

MT 2 WV 5 

NC 31 WY 2 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

September 1995 47 SIC Code 24 
Lumber and Wood Products Sector Notebook Project

SIC Code 24 48 September 1995

Exhibit 18

Releases for Lumber and Wood Products (SIC 24) in TRI, by Number of Facilities

(Releases reported in pounds/year)

Chemical Name

#/Facilities

Reporting

Chemical

Fugitive

Air

Point Air Water

Discharges

Underground

Injection

Land

Disposal

Total

Releases

Average

Releases

per

Facility

Arsenic Compounds 225 392 387 1661 0 5 2445 11

Chromium Compounds 223 397 392 2043 0 0 2832 13

Copper Compounds 222 397 397 2098 0 5 2897 13

Formaldehyde 69 318332 1832467 3500 0 1333 2155632 31241

Creosote 68 377646 641954 8016 0 943 1028559 15126

Arsenic 66 270 260 1451 0 5 1986 30

Copper 65 265 260 1192 0 250 1967 30

Chromium 63 255 245 1779 0 0 2279 36

Pentachlorophenol 36 5605 4206 2531 0 255 12597 350

Sulfuric Acid 25 10 48151 10 0 0 48171 1927

Ammonia 24 361205 264070 78011 0 7460 710746 29614

Methylenebis

(Phenylisocyanate)

24 658 9857 0 0 0 10515 438

Phenol 18 20855 210255 2850 0 5 233965 12998

Methanol 14 130145 554849 0 0 8 685002 48929

Toluene 14 215435 715331 0 0 0 930766 66483

Xylene (Mixed Isomers) 12 52437 1005851 0 0 0 1058288 88191

Acetone 10 205915 180720 0 0 0 386635 38664

Methyl Ethyl Ketone 9 8469 481703 0 0 0 490172 54464

Phosphoric Acid 9 0 20 0 0 0 20 2

Hydrochloric Acid 8 0 0 0 0 0 0 0

Methyl Isobutyl Ketone 8 70864 121782 0 0 0 192646 24081

Zinc Compounds 5 0 0 255 0 5 260 52

Ammonium Sulfate

(Solution)

4 0 5 0 5 1

Glycol Ethers 4 34600 65400 0 0 0 100000 25000

N-Butyl Alcohol 4 3199 89582 0 0 0 92781 23195

Naphthalene 4 10529 4852 0 0 1 15382 3846

Anthracene 3 2000 0 0 0 1 2001 667

Dibenzofuran 3 850 0 0 0 1 851 284

Ethylbenzene 2 1300 64644 0 0 0 65944 32972

Ethylene Glycol 2 1000 52900 0 0 0 53900 26950

Nitric Acid 2 0 1173 0 0 0 1173 587

Quinoline 2 272 0 0 0 1 273 137

Ammonium Nitrate

(Solution)

1 0 0 0 0 0

Antimony Compounds 1 0 0 0 0 0 0 0

Butyl Benzyl Phthalate 1 5 5 0 0 0 10 10

Chlorine 1 5 0 10 0 5 15

Di(2-Ethylhexyl) Phthalate 1 0 0 0 0 0 0 0

Dibutyl Phthalate 1 0 0 0 0 0 0 0

Dichloromethane 1 37000 0 0 0 37000 37000

Methyl Methacrylate 1 250 0 0 0 0 250 250

Styrene 1 0 0 0 0 0 0 0

Tetrachloroethylene 1 2 0 0 0 0 2 2

Toluene-2,4-Diisocyanate 1 68 36529 0 0 0 36597 36597

Zinc (Fume Or Dust) 1 5 5 5 0 0 15 15

Totals 491 1,860,637 6,388,247 105,417 0 10,278 8,364,579 17,036

Source: U.S. EPA, Toxics Release Inventory Database, 1993.

0 0

0 0

0 1
Sector Notebook Project Lumber and Wood Products

September 1995 49 SIC Code 24

Exhibit 19

Transfers for Lumber and Wood Product (SIC 24) in TRI, by Number of Facilities

(Transfers reported in pounds/year)

Chemical Name

# Facilities

Reporting

Chemical

POTW

Disharges Disposal Recycling Treatment

Energy

Recovery

Total

Transfers

Average

Transfers

per

Facility

Arsenic Compounds 225 0 90677 11192 101869 453

Chromium Compounds 223 0 82702 9494 92446 415

Copper Compounds 222 0 77164 9123 86287 389

Formaldehyde 69 120 1304 750 195 2369 34

Creosote 68 11502 1296906 18667 446558 636818 2410451 35448

Arsenic 66 16 81038 11910 92964 1409

Copper 65 35 54935 8090 63060 970

Chromium 63 7 99933 16200 116390 1847

Pentachlorophenol 36 1125 34860 1010 68963 40981 146939 4082

Sulfuric Acid 25 0 0 0

Ammonia 24 72250 1775 74025 3084

Methylenebis

(Phenylisocyanate)

24 600 511 1300 2411 100

Phenol 18 750 15 500 1100 2365 131

Methanol 14 598 2550 4700 5800 13648 975

Toluene 14 0 4300 4800 17700 43400 70200 5014

Xylene (Mixed Isomers) 12 5 16333 1750 78619 96707 8059

Acetone 10 0 9242 9242 924

Methyl Ethyl Ketone 9 0 1700 1800 25990 29490 3277

Phosphoric Acid 9 250 250 28

Hydrochloric Acid 8 0 0 0

Methyl Isobutyl Ketone 8 0 109577 109577 13697

Zinc Compounds 5 0 1505 250 1755 351

Ammonium Sulfate (Solution) 4 0 0 0

Glycol Ethers 4 3060 4500 7560 1890

N-Butyl Alcohol 4 0 750 250 9447 10447 2612

Naphthalene 4 0 751 751 188

Anthracene 3 0 255 255 85

Dibenzofuran 3 0 751 751 250

Ethylbenzene 2 0 1737 3420 5157 2579

Ethylene Glycol 2 0 0 0

Nitric Acid 2 0 0 0

Quinoline 2 0 251 251 126

Ammonium Nitrate (Solution) 1 0 0 0

Antimony Compounds 1 0 0 0

Butyl Benzyl Phthalate 1 0 0 0

Chlorine 1 0 0 0

Di(2-Ethylhexyl) Phthalate 1 0 0 0

Dibutyl Phthalate 1 0 0 0

Dichloromethane 1 0 750 750 750

Methyl Methacrylate 1 300 300 300

Styrene 1 0 250 250 250

Tetrachloroethylene 1 0 0 0

Toluene-2,4-Diisocyanate 1 0 0 0

Zinc (Fume Or Dust) 1 5 5 10 10

Totals 491 90,623 1,831,880 50,297 606,888 968,739 3,548,927 7,228

Source: U.S. EPA, Toxics Release Inventory Database, 1993.
Lumber and Wood Products Sector Notebook Project 

IV.B. Summary of Selected Chemicals Released 

The following is a synopsis of current scientific toxicity and fate 

information for the top chemicals (by weight) that facilities within this 

sector self-reported as released to the environment based upon 1993 TRI 

data. Because this section is based upon self-reported release data, it does 

not attempt to provide information on management practices employed 

by the sector to reduce the release of these chemicals. Information 

regarding pollutant release reductions over time may be available from 

EPA's TRI and 33/50 programs, or directly from the industrial trade 

associations that are listed in Section IX of this document. Since these 

descriptions are cursory, please consult the sources referenced below for a 

more detailed description of both the chemicals described in this section, 

and the chemicals that appear on the full list of TRI chemicals appearing 

in Section IV.A. 

The brief descriptions provided below were taken from the 1993 Toxics 

Release Inventory Public Data Release (EPA, 1994), the Hazardous 

Substances Data Bank (HSDB), and the Integrated Risk Information 

System (IRIS), both accessed via TOXNET1. The information contained 

below is based upon exposure assumptions that have been conducted 

using standard scientific procedures. The effects listed below must be 

taken in context of these exposure assumptions that are more fully 

explained within the full chemical profiles in HSDB. 

1 TOXNET is a computer system run by the National Library of Medicine that includes a number of 

toxicological databases managed by EPA, National Cancer Institute, and the National Institute for 

Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line at 1-

800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research 

Information System), DART (Developmental and Reproductive Toxicity Database), DBIR (Directory of 

Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center 

Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS (Integrated 

Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and TRI (Toxic 

Chemical Release Inventory). HSDB contains chemical-specific information on manufacturing and use, 

chemical and physical properties, safety and handling, toxicity and biomedical effects, pharmacology, 

environmental fate and exposure potential, exposure standards and regulations, monitoring and 

analysis methods, and additional references. 

SIC Code 24 50 September 1995 
Sector Notebook Project Lumber and Wood Products 

The top TRI releases for the lumber and wood products industry (SIC 24)

as whole include:

Acetone

Ammonia

Creosote

Formaldehyde

Methanol

Methyl ethyl ketone

Methyl isobutyl ketone

Phenol

Toluene

Xylenes (mixed isomers).

Acetone 

Toxicity. Acetone is irritating to the eyes, nose, and throat. Symptoms of 

exposure to large quantities of acetone may include headache, 

unsteadiness, confusion, lassitude, drowsiness, vomiting, and respiratory 

depression. 

Reactions of acetone (see environmental fate) in the lower atmosphere 

contribute to the formation of ground-level ozone. Ozone (a major 

component of urban smog) can affect the respiratory system, especially in 

sensitive individuals such as asthmatics or allergy sufferers. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. If released into water, acetone will be degraded by 

microorganisms or will evaporate into the atmosphere. Degradation by 

microorganisms will be the primary removal mechanism. 

Acetone is highly volatile, and once it reaches the troposphere (lower 

atmosphere), it will react with other gases, contributing to the formation 

of ground-level ozone and other air pollutants. EPA is reevaluating 

acetone's reactivity in the lower atmosphere to determine whether this 

contribution is significant. 

Physical Properties. Acetone is a volatile and flammable organic 

chemical. 

Note: Acetone was removed from the list of TRI chemicals on June 16, 1995 (60 

FR 31643) and will not be reported for 1994 or subsequent years. 

September 1995 51 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Ammonia 

Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, 

and upper respiratory system. 

Ecologically, ammonia is a source of nitrogen (an essential element for 

aquatic plant growth), and may therefore contribute to eutrophication of 

standing or slow-moving surface water, particularly in nitrogen-limited 

waters such as the Chesapeake Bay. In addition, aqueous ammonia is 

moderately toxic to aquatic organisms. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Ammonia combines with sulfate ions in the 

atmosphere and is washed out by rainfall, resulting in rapid return of 

ammonia to the soil and surface waters. 

Ammonia is a central compound in the environmental cycling of nitrogen. 

Ammonia in lakes, rivers, and streams is converted to nitrate. 

Physical Properties. Ammonia is a corrosive and severely irritating gas 

with a pungent odor. 

Formaldehyde 

Toxicity. Ingestion of formaldehyde leads to damage to the mucous 

membranes of mouth, throat, and intestinal tract; severe pain, vomiting, 

and diarrhea result. Inhalation of low concentrations can lead to irritation 

of the eyes, nose, and respiratory tract. Inhalation of high concentrations 

of formaldehyde causes severe damage to the respiratory system and to 

the heart, and may even lead to death. Other symptoms from exposure to 

formaldehyde include: headache, weakness, rapid heartbeat, symptoms of 

shock, gastroenteritis, central nervous system depression, vertigo, stupor, 

reduced body temperature, and coma. Repeated contact with skin 

promotes allergic reactions, dermatitis, irritation, and hardening. Contact 

with eyes causes injuries ranging from minor, transient injury to 

permanent blindness, depending on the concentration of the 

formaldehyde solution. In addition, menstrual disorders and secondary 

sterility have been reported in women exposed to formaldehyde. 

SIC Code 24 52 September 1995 
Sector Notebook Project Lumber and Wood Products 

Carcinogenicity. Formaldehyde is a probable human carcinogen via both 

inhalation and oral exposure, based on limited evidence in humans and 

sufficient evidence in animals. 

Environmental Fate. Most formaldehyde is released to the environment 

as a gas, and is rapidly broken down by sunlight and reactions with 

atmospheric ions. Its initial oxidation product, formic acid, is a 

component of acid rain. The rest of the atmospheric formaldehyde is 

removed via dry deposition, rain or dissolution into surface waters. 

Biodegradation of formaldehyde in water takes place in a few days. 

Volatilization of formaldehyde dissolved in water is low. 

Bioaccumulation of formaldehyde does not occur. 

When released onto the soil, aqueous solutions containing formaldehyde 

will leach through the soil. While formaldehyde is biodegradable under 

both aerobic and anaerobic conditions, its fate in soil and groundwater is 

unknown. 

Although formaldehyde is found in remote areas, it is probably not 

transported there, but rather is likely a result of the local generation of 

formaldehyde from longer-lived precursors which have been transported 

there. 

Methanol 

Toxicity. Methanol is readily absorbed from the gastrointestinal tract and 

the respiratory tract, and is toxic to humans in moderate to high doses. In 

the body, methanol is converted into formaldehyde and formic acid. 

Methanol is excreted as formic acid. Observed toxic effects at high dose 

levels generally include central nervous system damage and blindness. 

Long-term exposure to high levels of methanol via inhalation cause liver 

and blood damage in animals. 

Ecologically, methanol is expected to have low toxicity to aquatic 

organisms. Concentrations lethal to half the organisms of a test 

population are expected to exceed 1 mg methanol per liter water. 

Methanol is not likely to persist in water or to bioaccumulate in aquatic 

organisms. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Liquid methanol is likely to evaporate when left 

exposed. Methanol reacts in air to produce formaldehyde which 

September 1995 53 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

contributes to the formation of air pollutants. In the atmosphere it can 

react with other atmospheric chemicals or be washed out by rain. 

Methanol is readily degraded by microorganisms in soils and surface 

waters. 

Physical Properties. Methanol is highly flammable. 

Methyl Ethyl Ketone 

Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK) for 

short periods of time can cause adverse effects on the nervous system 

ranging from headaches, dizziness, nausea, and numbness in the fingers 

and toes to unconsciousness. Its vapors are irritating to the skin, eyes, 

nose, and throat and can damage the eyes. Repeated exposure to 

moderate to high amounts may cause liver and kidney effects. 

Carcinogenicity. No agreement exists over the carcinogenicity of MEK. 

One source believes MEK is a possible carcinogen in humans based on 

limited animal evidence. Other sources believe that there is insufficient 

evidence to make any statements about possible carcinogenicity. 

Environmental Fate. Most of the MEK released to the environment will 

end up in the atmosphere. MEK can contribute to the formation of air 

pollutants in the lower atmosphere. It can be degraded by 

microorganisms living in water and soil. 

Physical Properties. Methyl ethyl ketone is a flammable liquid. 

Toluene 

Toxicity. Inhalation or ingestion of toluene can cause headaches, 

confusion, weakness, and memory loss. Toluene may also affect the way 

the kidneys and liver function. 

Reactions of toluene (see environmental fate) in the atmosphere contribute 

to the formation of ozone in the lower atmosphere. Ozone can affect the 

respiratory system, especially in sensitive individuals such as asthma or 

allergy sufferers. 

Some studies have shown that unborn animals were harmed when high 

levels of toluene were inhaled by their mothers, although the same effects 

were not seen when the mothers were fed large quantities of toluene. 

Note that these results may reflect similar difficulties in humans. 

SIC Code 24 54 September 1995 
Sector Notebook Project Lumber and Wood Products 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. The majority of releases of toluene to land and water 

will evaporate. Toluene may also be degraded by microorganisms. Once 

volatized, toluene in the lower atmosphere will react with other 

atmospheric components contributing to the formation of ground-level 

ozone and other air pollutants. 

Physical Properties. Toluene is a volatile organic chemical. 

Xylene (Mixed Isomers) 

Toxicity. Xylenes are rapidly absorbed into the body after inhalation, 

ingestion, or skin contact. Short-term exposure of humans to high levels 

of xylenes can cause irritation of the skin, eyes, nose, and throat, difficulty 

in breathing, impaired lung function, impaired memory, and possible 

changes in the liver and kidneys. Both short- and long-term exposure to 

high concentrations can cause effects such as headaches, dizziness, 

confusion, and lack of muscle coordination. Reactions of xylenes (see 

environmental fate) in the atmosphere contribute to the formation of 

ozone in the lower atmosphere. Ozone can affect the respiratory system, 

especially in sensitive individuals such as asthma or allergy sufferers. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. The majority of releases to land and water will 

quickly evaporate, although some degradation by microorganisms will 

occur. 

Xylenes are moderately mobile in soils and may leach into groundwater, 

where they may persist for several years. 

Xylenes are volatile organic chemicals. As such, xylenes in the lower 

atmosphere will react with other atmospheric components, contributing to 

the formation of ground-level ozone and other air pollutants. 

September 1995 55 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

IV.C. Other Data Sources 

The Aerometric Information Retrieval System (AIRS) contains a wide 

range of information related to stationary sources of air pollution, 

including the emissions of a number of air pollutants which may be of 

concern within a particular industry. With the exception of volatile 

organic compounds (VOCs), there is little overlap with the TRI chemicals 

reported above. Exhibit 20 summarizes annual releases of carbon 

monoxide (CO), nitrogen dioxide (NO2), particulate matter of 10 microns 

or less (PM10), total particulates (PT), sulfur dioxide (SO2), and volatile 

organic compounds (VOCs). 

Exhibit 20

Pollutant Releases (Short Tons/Years)

Industry CO NO2 PM10 PT SO2 VOC 

U.S. Total 97,208,000 23,402,000 45,489,000 7,836,000 21,888,000 23,312,000 

Metal Mining 5,391 28,583 39,359 140,052 84,222 1,283 

Nonmetal Mining 4,525 28,804 59,305 167,948 24,129 1,736 

Lumber and Wood 

Products 

123,756 42,658 14,135 63,761 9,149 41,423 

Wood Furniture and 

Fixtures 

2,069 2,981 2,165 3,178 1,606 59,426 

Pulp and Paper 624,291 394,448 35,579 113,571 341,002 96,875 

Printing 8,463 4,915 399 1,031 1,728 101,537 

Inorganic Chemicals 166,147 108,575 4,107 39,082 182,189 52,091 

Organic Chemicals 146,947 236,826 26,493 44,860 132,459 201,888 

Petroleum Refining 419,311 380,641 18,787 36,877 648,153 309,058 

Rubber and Misc. Plastic 

Products 

2,090 11,914 2,407 5,355 29,364 140,741 

Stone, Clay, Glass, and 

Concrete 

58,043 338,482 74,623 171,853 339,216 30,262 

Iron and Steel 1,518,642 138,985 42,368 83,017 238,268 82,292 

Nonferrous Metals 448,758 55,658 20,074 22,490 373,007 27,375 

Fabricated Metals 3,851 16,424 1,185 3,136 4,019 102,186 

Electronics 367 1,129 207 293 453 4,854 

Motor Vehicles, Bodies, 

Parts, and Accessories 

35,303 23,725 2,406 12,853 25,462 101,275 

Dry Cleaning 101 179 3 28 152 7,310 

Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995. 

SIC Code 24 56 September 1995 
Sector Notebook Project Lumber and Wood Products 

IV.D. Comparison of Toxic Release Inventory Between Selected Industries 

The following information is presented as a comparison of pollutant 

release and transfer data across industrial categories. It is provided to 

give a general sense as to the relative scale of releases and transfers within 

each sector profiled under this project. Please note that the following 

table does not contain releases and transfers for industrial categories that 

are not included in this project, and thus cannot be used to draw 

conclusions regarding the total release and transfer amounts that are 

reported to TRI. Similar information is available within the annual TRI 

Public Data Release book. 

Exhibit 21 is a graphical representation of a summary of the 1993 TRI data 

for the Lumber and Wood Products Industry and the other sectors 

profiled in separate notebooks. The bar graph presents the total TRI 

releases and total transfers on the left axis and the triangle points show 

the average releases per facility on the right axis. Industry sectors are 

presented in the order of increasing total TRI releases. The graph is based 

on the data shown in Exhibit 22 and is meant to facilitate comparisons 

between the relative amounts of releases, transfers, and releases per 

facility both within and between these sectors. The reader should note, 

however, that differences in the proportion of facilities captured by TRI 

exist between industry sectors. This can be a factor of poor SIC matching 

and relative differences in the number of facilities reporting to TRI from 

the various sectors. In the case of Lumber and Wood Products Industry, 

the 1993 TRI data presented here covers 491 facilities. These facilities 

listed SIC 24 Lumber and Wood Products as a primary SIC code. 

September 1995 57 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 21 - Bar Graph 

0 

100 

200 

300 

400 

500 

600 

700 

Total Pounds (millions) 

0 

200,000 

400,000 

600,000 

800,000 

1,000,000 

Average Releases per Facility (lbs.) 

36 

24 

32 

27 

25 

2911 

34 

371 

331 

30 

286 

26 

281 

333, 334 

Total Releases Total Transfers Avg. Releases/Facility 

SIC 

Range 

Industry Sector SIC 

Range 

Industry Sector SIC 

Range 

Industry Sector 

36 Electronic Equipment and 

Components 

2911 Petroleum Refining 286 Organic Chemical Mfg. 

24 Lumber and Wood 

Products 

34 Fabricated Metals 26 Pulp and Paper 

32 Stone, Clay, and Concrete 371 Motor Vehicles, Bodies, 

Parts, and Accessories 

281 Inorganic Chemical Mfg. 

27 Printing 331 Iron and Steel 333,334 Nonferrous Metals 

25 Wood Furniture and 

Fixtures 

30 Rubber and Misc. 

Plastics 

SIC Code 24 58 September 1995
Sector Notebook Project Lumber and Wood Products 

Exhibit 22

Toxic Release Inventory Data for Selected Industries

Releases Transfers Total 

Industry Sector SIC 

Range 

# TRI 

Facilitie 

s 

Total Releases 

(106 pounds) 

Average 

Releases per 

Facility 

(pounds) 

1993 Total (106 

pounds) 

Average 

Transfers per 

Facility (pounds) 

Releases + 

Transfers 

(106 

pounds) 

Average 

Release+ 

Transfers per 

Facility 

(pounds) 

Stone, Clay, and 

Concrete 

32 634 26.6 41,895 2.2 3,500 28.2 46,000 

Lumber and Wood 

Products 

24 491 8.4 17,036 3.5 7,228 11.9 24,000 

Furniture and 

Fixtures 

25 313 42.2 134,883 4.2 13,455 46.4 148,000 

Printing 2711-

2789 

318 36.5 115,000 10.2 732,000 46.7 147,000 

Electronics/Comp 

uters 

36 406 6.7 16,520 47.1 115,917 53.7 133,000 

Rubber and Misc. 

Plastics 

30 1,579 118.4 74,986 45.0 28,537 163.4 104,000 

Motor Vehicle, 

Bodies, Parts and 

Accessories 

371 609 79.3 130,158 145.5 238,938 224.8 369,000 

Pulp and paper 2611-

2631 

309 169.7 549,000 48.4 157,080 218.1 706,000 

Inorganic Chem. 

Mfg. 

2812-

2819 

555 179.6 324,000 70.0 126,000 249.7 450,000 

Petroleum 

Refining 

2911 156 64.3 412,000 417.5 2,676,000 481.9 3,088,000 

Fabricated Metals 34 2,363 72.0 30,476 195.7 82,802 267.7 123,000 

Iron and Steel 3312-

3313 

3321-

3325 

381 85.8 225,000 609.5 1,600,000 695.3 1,825,000 

Nonferrous Metals 333, 334 208 182.5 877,269 98.2 472,335 280.7 1,349,000 

Organic Chemical 

Mfg. 

2861-

2869 

417 151.6 364,000 286.7 688,000 438.4 1,052,000 

Metal Mining 10 Industry sector not subject to TRI reporting 

Nonmetal Mining 14 Industry sector not subject to TRI reporting 

Dry Cleaning 7215, 

7216, 

7218 

Industry sector not subject to TRI reporting 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

September 1995 59 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

V. POLLUTION PREVENTION OPPORTUNITIES 

The best way to reduce pollution is to prevent it in the first place. Some 

companies have creatively implemented pollution prevention techniques 

that improve efficiency and increase profits while at the same time 

minimizing environmental impacts. This can be done in many ways such 

as reducing material inputs, re-engineering processes to reuse byproducts, improving management practices, and employing substitution 

of toxic chemicals. Some smaller facilities are able to actually get below 

regulatory thresholds just by reducing pollutant releases through 

aggressive pollution prevention policies. 

In order to encourage these approaches, this section provides both general 

and company-specific descriptions of some pollution prevention advances 

that have been implemented within the lumber and wood products 

industry. While the list is not exhaustive, it does provide core 

information that can be used as the starting point for facilities interested 

in beginning their own pollution prevention projects. When possible, this 

section provides information from real activities that can, or are being 

implemented by this sector -- including a discussion of associated costs, 

time frames, and expected rates of return. This section provides summary 

information from activities that may be, or are being implemented by this 

sector. When possible, information is provided that gives the context in 

which the techniques can be effectively used. Please note that the 

activities described in this section do not necessarily apply to all facilities 

that fall within this sector. Facility-specific conditions must be carefully 

considered when pollution prevention options are evaluated, and the full 

impacts of the change must examine how each option affects, air, land, 

and water pollutant releases. 

Surface Protection 

Several alternative manufacturing methods are part of the industry’s 

pollution prevention efforts. One common alternative is to replace 

chemical treatment with another type of treatment to achieve surface 

protection. For example, the need for surface treatment would be 

decreased if efforts were made to dry the wood to reduce water content 

(high water content leads to sapstain). Due to economies of scale, this 

option may not be economically viable for a smaller mill. 

Another pollution prevention option is the use of high velocity spray 

systems that generate fewer process residuals and less drippage. 

However, a small production volume may not favor this option since 

SIC Code 24 60 September 1995 
Sector Notebook Project Lumber and Wood Products 

spray systems require a larger flow of wood through the systems to be 

economically or technically feasible. 

Other pollution prevention strategies relating to surface protection 

include: 1) local and general ventilation within the cutting process area to 

reduce dust which would accumulate on wood; 2) blowing wood with air 

to further reduce sawdust on wood prior to surface protection; and 3) the 

use of drainage collection devices on roof tops to keep rainwater away 

from process wastes. For wastes that cannot be reduced at the source, 

generators may consider used surface protectant recycling as the next best 

option. 

Panel Products 

Air emissions from panel manufacturing are significantly greater than 

releases to water or land. The following information on pollution 

prevention options for the wood panel products industry (including 

veneer/plywood and reconstituted wood products) is from Martin and 

Northeim's summary. 

Alternative Fiber Sources 

One pollution prevention opportunity for the reconstituted wood panel 

industry is to search for alternative sources of wood fiber. This can be 

done in two ways: utilizing recycled wood waste and using existing 

agricultural fibers. 

Increasing prices for raw wood furnish have led some firms to develop 

programs to recycle wood waste into chips for PB production. These 

firms collect construction site debris, discarded household items, crates, 

and used pallets for eventual use as PB furnish. Beyond finding sources, 

an ideal fiber recycling program includes extensive training and research 

on what materials are suitable, careful quality control of the recycled 

materials, and cleaning materials to remove foreign matter. There are 

many hurdles to properly cleaning the material because it is difficult to 

process different kinds of material and maintain a quality product. 

A second alternative source for fiber is agricultural fiber, which can come 

from two sources: agricultural crops grown expressly for fiber (e.g., kenaf 

and bagasse) and residues of crops grown for other purposes (e.g., corn 

stalks/cobs and cotton stalks). Currently, two plants are being built in the 

U.S. that will use agricultural fiber to manufacture composite panels. In 

terms of potential availability, the amount of residual fiber generated by 

U.S. agriculture far exceeds present and future fiber requirements for 

September 1995 61 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

composite panel manufacture. The feasibility of such a substitution, 

however, depends on many factors such as product quality, cost, and 

current uses of agriculture residues. 

Alternative Adhesives 

Other pollution prevention options in the panel products industry involve 

adhesive substitution. This involves replacing existing adhesives with 

less toxic formulations. There are a number of innovative adhesive 

options currently available for use in the panel products industry. 

MDI Substitution 

Based on price alone, there seems to be little incentive for manufacturers 

to switch from PF or UF to MDI adhesives. However, since the early 80's, 

one third of the OSB industry has switched from PF to MDI adhesives. 

According to their manufacturers, there are several environmental 

advantages to using these adhesives. Because MDI adhesives are capable 

of bonding wood flakes with a higher moisture content, less dryer energy 

is required to dry flakes suitable for MDI bonding. Other advantages to 

using MDI adhesives are lower press temperatures and shorter press 

cycles, both of which may lead to reduced press emissions. However, 

there are other concerns with respect to the use of MDI adhesives. Some 

companies are opposed to MDI substitution for reasons such as worker 

toxics exposure, potential acute impacts of possible spills, and 

inconsistency with toxic use reduction objectives. Manufacturers of MDI 

state that safe exposure levels are obtainable through good engineering 

controls which include making sure that blenders are well sealed, and 

that the blending and forming areas are well ventilated. 

High Moisture Adhesives 

Switching to an adhesive that is capable of bonding a high moisture 

furnish eliminates the need to dry wood to a low moisture content. Dryer 

energy and temperature can be reduced because less water must be 

removed from the wood. Press temperature can also be lowered since 

heat transfer is more efficient in high moisture furnish, reducing VOC 

emissions. 

The gluing of high moisture content wood has become an established 

practice in plywood manufacture. Many OSB plants are switching to high 

moisture bonding adhesives with the primary goals of reducing dryer 

emissions and possibly reducing wood drying costs. Efforts have been 

made to improve phenolic resin technology to allow better bonding in the 

SIC Code 24 62 September 1995 
Sector Notebook Project Lumber and Wood Products 

presence of water. The primary incentive for bonding high moisture 

veneer is a reduction in adhesive consumption. In the Southern plywood 

industry; where dryout is a problem, a dramatic reduction in adhesive 

use has been achieved by gluing high moisture veneer. 

Naturally-derived Adhesives 

Spurred by rapid price increases of petroleum-derived chemicals in 

adhesives such as PF and UF, chemical material suppliers, forest products 

companies, and wood adhesive/binder suppliers are expending research 

and development funds to search for renewable raw material sources. 

Substitutes could replace entirely, or at least partially, petroleum-derived 

chemicals now used in the manufacture of wood adhesives. Naturallyderived adhesives are included in this profile as a pollution prevention 

opportunity because of the potential to use renewable resources, which in 

many cases are by-products of other processes. 

Furfuryl Alcohol Resins 

Resins manufactured from furfuryl alcohol are being evaluated as an 

alternative low-VOC binder to substitute for PF resins. Unlike PF resins, 

furfuryl alcohol resins are stored stable at ambient temperatures, without 

refrigeration. As delivered, furfuryl alcohol resin contains very low 

amounts of volatile components. Upon curing, it reduces 80 to 90 percent 

of total VOC emissions, and reduces Hazardous Air Pollutants (HAPs) by 

the same amount. The furfuryl alcohol system offers the same relative 

speed of cure as the PF resin systems. 

Furfuryl alcohol resin is currently in the experimental stage of 

development. The industry has shown little interest in the resin because 

of its high cost; which is twice that of a PF resin. However, cost analyses 

performed for the insulation industry show that using the resin to meet 

future HAP standards is cheaper than purchasing and operating control 

devices such as scrubbers. The same is likely true for the wood products 

industry. 

Lignin Adhesives 

Lignin is an aromatic polymer that makes up one of the three major 

components of wood (cellulose and hemicellulose are the others). The 

abundance of lignin as a waste product in pulp mills has made it a 

desirable raw material alternative to nonrenewable petroleum-derived 

chemicals in the production of wood adhesives. 

September 1995 63 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Until recently, no more than 20 to 30 percent of lignin could be 

substituted into PF resins because cure times increased as the amount of 

lignin increased. Another drawback is that lignin adhesives have low 

cross-linking and strength. However, a new approach has recently been 

developed that can substitute large amounts of kraft lignin for PF 

adhesives while actually increasing cure speed and board strength. 

Currently, Westvaco is the only company in the U.S. that operates a 

commercial lignin extraction facility. The capital cost of a new 

commercial lignin extraction facility compared to the capital cost of a new 

phenol plant is estimated to be almost equal per pound of product 

produced. However, because the selling price of lignin is only $0.32-0.34, 

compared to the selling price of phenol which is $.45/solid pound and 

rising, there is more of an economic incentive to build a new phenol plant 

than a lignin extraction facility. 

Polyvinyl acetate (PVA) 

There have been some mill trials and some small quantities of hardwood 

plywood made with cross-linked polyvinyl acetate (PVA) adhesives. 

Blends of PVA and UF are also sometimes used in the manufacture of 

hardwood plywood. Cross-linked PVAs are light in color, are compatible 

with the hardwood plywood manufacturing process, and don't require 

additional equipment. Concerns have been expressed about the potential 

of airborne release of vinyl monomers. PVA adhesives are considerably 

higher in cost than UF adhesives. 

Alternative Manufacturing Processes 

Veneer and Plywood Adhesive Reduction 

In the softwood plywood industry, a common waste generated by the 

typical spray-line layup system is over-spray. A more efficient way of 

applying adhesive to veneer is by foam extrusion, a process in which 

foamed adhesive is forced under pressure to the extrusion head. This 

process better concentrates the glue stream onto the veneer, resulting in 

less wasted adhesive and less chance of adhesive dryout before pressing. 

In terms of economics, the combination of less waste and lower spread 

rates when using foam extruders can add up to savings in the 20 to 31 

percent range, depending on the type of equipment used. 

Another pollution prevention option in the softwood plywood industry is 

the variable application rate strategy (VARS). The amount of adhesive 

required to bond veneer varies with moisture content. For example, high 

SIC Code 24 64 September 1995 
Sector Notebook Project Lumber and Wood Products 

moisture veneer requires less glue than low moisture veneer because 

there is less migration of water from the glue into the veneer. Although 

the moisture content of veneer varies at a typical plywood mill, glue is 

applied at a constant rate to prevent dryout of low moisture veneer. A 

1992 study by Faust and Borders outlined in Forest Products Journal, 

investigated the use of the glue application rate with respect to improved 

bond quality and reduced resin consumption. The variable application 

rate strategy (VARS) they developed adjusted the glue spread rate for 

each individual plywood panel according to its moisture content. 

Process-sensing and control technology has been developed for the 

practical application of VARS. Sensor technology is currently available 

for on-line adjustment and measurement of veneer moisture content and 

temperature. In addition to compensating for problem bonding 

conditions that occur unexpectedly during production, the greatest 

benefit of VARS from a pollution prevention standpoint is a reduction in 

adhesive consumption and, consequently a reduction in plant emissions. 

Alternative Dryers 

There are other process modifications that may be implemented to reduce 

emissions while drying green furnish for reconstituted wood panel 

manufacture. Researchers are currently investigating the use of 

alternative drying methods for raw wood furnish. 

Rotary drum dryers are used in the OSB industry. These are typically 

characterized by high-temperature drying air, aggressive handling of 

strands, and short product-retention times. The adverse affects of these 

characteristics include VOC emissions and strand degradation. Research 

has shown that low-temperature drying reduces VOC emissions. 

However, this requires that the furnish be retained in the dryer for a 

longer period of time which is difficult to achieve in a rotary dryer. It has 

been found that conveyor belt dryers generate less VOC emissions than 

rotary dryers. Temperatures of less than 400°F and very low volumes of 

exhaust gases are possible with conveyor dryers, resulting in low 

emission levels of VOC, while virtually eliminating strand damage within 

the dryer. Conveyor dryers can also be used to dry PB furnish. 

The three pass high velocity (3PHV) rotary drum dryer is a major 

breakthrough in rotary drum drying technology that has the potential to 

reduce VOC emissions significantly (see Exhibit 9). The 3PHV is a 

rotating cylindrical drum consisting of three, concentric, interlocking 

cylinders. Hot gases enter the outermost cylinder with the wood chips 

and progress through the intermediate and then the inner drum shells in 

a serpentine flow path. This flow path direction is the opposite of that in 

September 1995 65 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

the conventional three-pass dryer. This reverse air flow may reduce VOC 

emissions. 

In the first pass, the 3PHV dryer allows smaller, dried particles to pass 

through the slower moving mass of larger, wetter particles in an area 

bounded by the outer and intermediate drum cylinders. This area is 

much larger than the area of the inner drum of conventional triple pass 

dryers. As the larger particles are dried, they will "catch up" with the 

smaller faster moving particles in an area bounded by the intermediate 

(second pass) drum cylinder. Here, airflow velocities become high 

enough to convey the entire mass of particles out of the drying portion of 

the drum and into the inner (third pass) drum cylinder where they will be 

conveyed out of the dryer. This action prevents the product from 

reaching temperatures in excess of the wet bulb temperature, thus 

reducing carbon monoxide and hydrocarbon emissions associated with 

pyrolysis and combustion of the wood chips. 

Wood Preserving 

Water-borne preservatives produce less waste than oil-borne 

preservatives because process wastewater is reused rather than 

discharged. In addition, well designed treatment plants, good treatment 

practices, effective housekeeping, and employee training also help reduce 

waste at the source. 

Well designed treatment plants may have enclosed treatment buildings, 

covered drip pads with liners, automatic lumber handling systems, 

centralized tank farms with spill containment, and air ventilation systems. 

The RCRA standards in 40 CFR 264 and 265 require that drip pads must 

contain drippage, be free of cracks and gaps, and be cleaned and 

inspected. Plants can also be designed to minimize mist or droplet 

emissions from cylinders and work tanks through the use of air exchange 

systems and cylinder and tank venting. 

Treatment practices are also important for preventing pollution. Ensuring 

that wood stock is clean prior to treatment will prevent dirt, sawdust, and 

other debris from accumulating in the treatment system. To prevent 

debris buildup, wood can be covered during shipment and/or powerwashed when necessary before it enters the treatment plant. Strip pumps 

may be installed to continuously return residual chemical solutions to the 

work tank, resulting in less dripping when the cylinder doors are opened. 

If treating cylinders are tilted slightly away from the drip pad, there is 

also less spillage when opening the cylinder doors. 

SIC Code 24 66 September 1995 
Sector Notebook Project Lumber and Wood Products 

Housekeeping is an integral part of waste minimization efforts. All 

tanks, mixing systems, treating cylinders, drip pads, and spill 

containments should be inspected regularly for leaks. Drip pads and 

collection areas should be kept clean. Storage yards should be inspected 

daily, and any drippage detected should be cleaned up within 24 hours. 

Several other preservatives have been proposed as alternatives to 

traditional preservatives. For example, wood can be treated with borates 

using both pressure and non-pressure processes. However, because they 

are highly susceptible to leaching, borates cannot be used to preserve 

wood that will be in contact with the ground or exposed to the weather 

(e.g., decking). 

Ammoniacal copper/quarternary ammonium (ACQ) is another proposed 

alternative. Initial above-ground field test data show that ACQ is 

effective for softwood and hardwood protection. Other alternative 

preservatives may include copper-8-quinolinolate (Cu8), copper 

naphthanate, zinc naphthanate, quarternary NH4 compounds (QAC), and 

zinc sulfate. 

Treatment processes may vary in their ability to minimize waste. For 

example, the empty-cell process uses less carrier oil than the full-cell 

process for oil-borne preservatives. The modified full-cell treatment 

reduces the uptake of treating solution and minimizes the amount of 

dripping for water-borne preservatives. 

Pollution Prevention Case Studies 

Reconstituted Wood Products 

By late 1995, CanFibre hopes to start up its first plant to produce MDF 

using 100 percent post-consumer waste and PF adhesives. The plant (the 

first of its kind in North America) will be located near Toronto, Ontario. 

Approximately 1.2 million ft3 per year of structural MDF will be 

produced from recycled urban waste such as waste wood, cardboard, 

drink containers, newspaper, etc. The plant will have two significant cost 

advantages over conventional MDF plants: (1) the costs of post-consumer 

waste is currently negative, and (2) savings in freight costs due to the 

plant's location near an urban site (most existing MDF plants are remotely 

located and the cost of hauling wood waste back to these mills is high). 

The net mill cost for the process used by the firm's Toronto plant is 

estimated to be $183/million square feet (MSF) versus $228/MSF for a 

conventional plant. The company plans to build a total of nine plants in 

September 1995 67 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

North America: six in the U.S. and three in Canada. All plants will use 

100 percent post-consumer waste and PF adhesives. 

Wood Preserving 

Perry Builders, Inc. employs 20 people at its Henderson pressure wood 

preserving manufacturing facility. Perry Builders recognizes that each 

wood treater has an important responsibility in properly handling and 

disposing of the wastes it produces and is committed to meeting this 

challenge. Perry uses a water-borne chemical preservative; chromated 

copper arsenate, to treat lumber, plywood, timbers, and other wood 

products for decks, fences, and other outdoor uses. Hazardous waste 

results from contact of sawdust, wood chips, and dirt with the 

preservative. It has successfully minimized its hazardous waste 

generation by 80 percent in two years with the implementation of a lowcost waste minimization program. In 1987, Perry Builders generated 15 

drums of hazardous waste with a disposal cost of $2,380. By 1989 Perry 

Builders reduced its disposal cost to $310 by generating only two drums. 

This reduction was achieved by changing both equipment and processes 

to achieve a fully integrated closed system in which the application, 

receipt, transfer, and storage of the preservation takes place in a contained 

area. 

The goal is to apply the preservative to the wood while minimizing the 

loss of the preservative as a waste. By holding the lumber in the 

treatment chamber longer to allow drippage, and by using a vacuum 

pump to further dry the lumber, the treatment solution remains in the 

chamber and does not come into contact with scrap material and dirt. As 

an incentive to employees to assure adequate drying time, management 

instituted pay based on hourly wages rather than an amount of lumber 

treated. A roof over the area housing the treated lumber prevents runoff 

during rainfall. 

Perry Builders estimates that the cost of the vacuum pump, the roof, and 

the increased drying time will be recovered in five years through reduced 

disposal costs. There is also another economic benefit-since the drier 

lumber weighs less, more footage of lumber can be shipped on each truck, 

thereby reducing freight costs. 

SIC Code 24 68 September 1995 
Sector Notebook Project Lumber and Wood Products 

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 

This section discusses the Federal statutes and regulations that may apply 

to this sector. The purpose of this section is to highlight, and briefly 

describe the applicable Federal requirements, and to provide citations for 

more detailed information. The three following sections are included. 

• Section VI.A contains a general overview of major statutes 

• Section VI.B contains a list of regulations specific to this industry 

• Section VI.C contains a list of pending and proposed regulations 

The descriptions within Section VI are intended solely for general 

information. Depending upon the nature or scope of the activities at a 

particular facility, these summaries may or may not necessarily describe 

all applicable environmental requirements. Moreover, they do not 

constitute formal interpretations or clarifications of the statutes and 

regulations. For further information, readers should consult the Code of 

Federal Regulations and other state or local regulatory agencies. EPA 

Hotline contacts are also provided for each major statute. 

VI.A. General Description of Major Statutes 

Resource Conservation And Recovery Act 

The Resource Conservation And Recovery Act (RCRA) of 1976 which 

amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and 

hazardous (Subtitle C) waste management activities. The Hazardous and 

Solid Waste Amendments (HSWA) of 1984 strengthened RCRA’s waste 

management provisions and added Subtitle I, which governs 

underground storage tanks (USTs). 

Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts 

260-299) establish a “cradle-to-grave” system governing hazardous waste 

from the point of generation to disposal. RCRA hazardous wastes include 

the specific materials listed in the regulations (commercial chemical 

products, designated with the code "P" or "U"; hazardous wastes from 

specific industries/sources, designated with the code "K"; or hazardous 

wastes from non-specific sources, designated with the code "F") or 

materials which exhibit a hazardous waste characteristic (ignitability, 

corrosivity, reactivity, or toxicity and designated with the code "D"). 

September 1995 69 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Regulated entities that generate hazardous waste are subject to waste 

accumulation, manifesting, and recordkeeping standards. Facilities that 

treat, store, or dispose of hazardous waste must obtain a permit, either 

from EPA or from a State agency which EPA has authorized to implement 

the permitting program. Subtitle C permits contain general facility 

standards such as contingency plans, emergency procedures, 

recordkeeping and reporting requirements, financial assurance 

mechanisms, and unit-specific standards. RCRA also contains provisions 

(40 CFR Part 264 Subpart S and §264.10) for conducting corrective actions 

which govern the cleanup of releases of hazardous waste or constituents 

from solid waste management units at RCRA-regulated facilities. 

Although RCRA is a Federal statute, many States implement the RCRA 

program. Currently, EPA has delegated its authority to implement 

various provisions of RCRA to 46 of the 50 States. 

Most RCRA requirements are not industry specific but apply to any 

company that transports, treats, stores, or disposes of hazardous waste. 

Here are some important RCRA regulatory requirements: 

• Identification of Solid and Hazardous Wastes (40 CFR Part 261) 

lays out the procedure every generator should follow to determine 

whether the material created is considered a hazardous waste, 

solid waste, or is exempted from regulation. 

• Standards for Generators of Hazardous Waste (40 CFR Part 262) 

establishes the responsibilities of hazardous waste generators 

including obtaining an ID number, preparing a manifest, ensuring 

proper packaging and labeling, meeting standards for waste 

accumulation units, and recordkeeping and reporting 

requirements. Generators can accumulate hazardous waste for up 

to 90 days (or 180 days depending on the amount of waste 

generated) without obtaining a permit. 

• Land Disposal Restrictions (LDRs) are regulations prohibiting the 

disposal of hazardous waste on land without prior treatment. 

Under the LDRs (40 CFR 268), materials must meet land disposal 

restriction (LDR) treatment standards prior to placement in a 

RCRA land disposal unit (landfill, land treatment unit, waste pile, 

or surface impoundment). Wastes subject to the LDRs include 

solvents, electroplating wastes, heavy metals, and acids. 

Generators of waste subject to the LDRs must provide notification 

of such to the designated TSD facility to ensure proper treatment 

prior to disposal. 

SIC Code 24 70 September 1995 
Sector Notebook Project Lumber and Wood Products 

• Used Oil Management Standards (40 CFR Part 279) impose 

management requirements affecting the storage, transportation, 

burning, processing, and re-refining of the used oil. For parties 

that merely generate used oil, regulations establish storage 

standards. For a party considered a used oil marketer (one who 

generates and sells off-specification used oil directly to a used oil 

burner), additional tracking and paperwork requirements must be 

satisfied. 

• Tanks and Containers used to store hazardous waste with a high 

volatile organic concentration must meet emission standards under 

RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require 

generators to test the waste to determine the concentration of the 

waste, to satisfy tank and container emissions standards, and to 

inspect and monitor regulated units. These regulations apply to all 

facilities who store such waste, including generators operating 

under the 90-day accumulation rule. 

• Underground Storage Tanks (USTs) containing petroleum and 

hazardous substance are regulated under Subtitle I of RCRA. 

Subtitle I regulations (40 CFR Part 280) contain tank design and 

release detection requirements, as well as financial responsibility 

and corrective action standards for USTs. The UST program also 

establishes increasingly stringent standards, including upgrade 

requirements for existing tanks, that must be met by 1998. 

• Boilers and Industrial Furnaces (BIFs) that use or burn fuel 

containing hazardous waste must comply with strict design and 

operating standards. BIF regulations (40 CFR Part 266, Subpart H) 

address unit design, provide performance standards, require 

emissions monitoring, and restrict the type of waste that may be 

burned. 

EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to questions 

and distributes guidance regarding all RCRA regulations. The RCRA Hotline 

operates weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding Federal holidays. 

Comprehensive Environmental Response, Compensation, And Liability Act 

The Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA), a 1980 law commonly known as Superfund, 

authorizes EPA to respond to releases, or threatened releases, of 

hazardous substances that may endanger public health, welfare, or the 

environment. CERCLA also enables EPA to force parties responsible for 

environmental contamination to clean it up or to reimburse the Superfund 

for response costs incurred by EPA. The Superfund Amendments and 

September 1995 71 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Reauthorization Act (SARA) of 1986 revised various sections of CERCLA, 

extended the taxing authority for the Superfund, and created a freestanding law, SARA Title III, also known as the Emergency Planning and 

Community Right-to-Know Act (EPCRA). 

The CERCLA hazardous substance release reporting regulations (40 

CFR Part 302) direct the person in charge of a facility to report to the 

National Response Center (NRC) any environmental release of a 

hazardous substance which exceeds a reportable quantity. Reportable 

quantities are defined and listed in 40 CFR § 302.4. A release report may 

trigger a response by EPA, or by one or more Federal or State emergency 

response authorities. 

EPA implements hazardous substance responses according to 

procedures outlined in the National Oil and Hazardous Substances 

Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP includes 

provisions for permanent cleanups, known as remedial actions, and other 

cleanups referred to as "removals." EPA generally takes remedial actions 

only at sites on the National Priorities List (NPL), which currently 

includes approximately 1300 sites. Both EPA and states can act at other 

sites; however, EPA provides responsible parties the opportunity to 

conduct removal and remedial actions and encourages community 

involvement throughout the Superfund response process. 

EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, answers questions 

and references guidance pertaining to the Superfund program. The CERCLA 

Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding Federal 

holidays. 

Emergency Planning And Community Right-To-Know Act 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 

created the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), a statute designed to improve 

community access to information about chemical hazards and to facilitate 

the development of chemical emergency response plans by State and local 

governments. EPCRA required the establishment of State emergency 

response commissions (SERCs), responsible for coordinating certain 

emergency response activities and for appointing local emergency 

planning committees (LEPCs). 

EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four 

types of reporting obligations for facilities which store or manage 

specified chemicals: 

SIC Code 24 72 September 1995 
Sector Notebook Project Lumber and Wood Products 

• EPCRA §302 requires facilities to notify the SERC and LEPC of the 

presence of any "extremely hazardous substance" (the list of such 

substances is in 40 CFR Part 355, Appendices A and B) if it has 

such substance in excess of the substance's threshold planning 

quantity, and directs the facility to appoint an emergency response 

coordinator. 

• EPCRA §304 requires the facility to notify the SERC and the LEPC 

in the event of a release exceeding the reportable quantity of a 

CERCLA hazardous substance or an EPCRA extremely hazardous 

substance. 

• EPCRA §§311 and 312 require a facility at which a hazardous 

chemical, as defined by the Occupational Safety and Health Act, is 

present in an amount exceeding a specified threshold to submit to 

the SERC, LEPC, and local fire department material safety data 

sheets (MSDSs) or lists of MSDSs and hazardous chemical 

inventory forms (also known as Tier I and II forms). This 

information helps the local government respond in the event of a 

spill or release of the chemical. 

• EPCRA §313 requires manufacturing facilities included in SIC 

codes 20 through 39, which have ten or more employees, and 

which manufacture, process, or use specified chemicals in amounts 

greater than threshold quantities, to submit an annual toxic 

chemical release report. This report, commonly known as the Form 

R, covers releases and transfers of toxic chemicals to various 

facilities and environmental media, and allows EPA to compile the 

national Toxic Release Inventory (TRI) database. 

All information submitted pursuant to EPCRA regulations is publicly 

accessible, unless protected by a trade secret claim. 

EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes 

guidance regarding the emergency planning and community right-to-know 

regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., 

EST, excluding Federal holidays. 

Clean Water Act 

The primary objective of the Federal Water Pollution Control Act, 

commonly referred to as the Clean Water Act (CWA), is to restore and 

maintain the chemical, physical, and biological integrity of the nation's 

surface waters. Pollutants regulated under the CWA include "priority" 

pollutants, including various toxic pollutants; "conventional" pollutants, 

September 1995 73 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

such as biochemical oxygen demand (BOD), total suspended solids (TSS), 

fecal coliform, oil and grease, and pH; and "non-conventional" pollutants, 

including any pollutant not identified as either conventional or priority. 

The CWA regulates both direct and indirect discharges. The National 

Pollutant Discharge Elimination System (NPDES) program (CWA §402) 

controls direct discharges into navigable waters. Direct discharges or 

"point source" discharges are from sources such as pipes and sewers. 

NPDES permits, issued by either EPA or an authorized State (EPA has 

presently authorized forty States to administer the NPDES program), 

contain industry-specific, technology-based and/or water quality-based 

limits, and establish pollutant monitoring and reporting requirements. A 

facility that intends to discharge into the nation's waters must obtain a 

permit prior to initiating its discharge. A permit applicant must provide 

quantitative analytical data identifying the types of pollutants present in 

the facility's effluent. The permit will then set forth the conditions and 

effluent limitations under which a facility may make a discharge. 

A NPDES permit may also include discharge limits based on Federal or 

State water quality criteria or standards, that were designed to protect 

designated uses of surface waters, such as supporting aquatic life or 

recreation. These standards, unlike the technological standards, generally 

do not take into account technological feasibility or costs. Water quality 

criteria and standards vary from State to State, and site to site, depending 

on the use classification of the receiving body of water. Most States 

follow EPA guidelines which propose aquatic life and human health 

criteria for many of the 126 priority pollutants. 

Storm Water Discharges 

In 1987 the CWA was amended to require EPA to establish a program to 

address storm water discharges. In response, EPA promulgated the 

NPDES storm water permit application regulations. Storm water 

discharge associated with industrial activity means the discharge from 

any conveyance which is used for collecting and conveying storm water 

and which is directly related to manufacturing, processing or raw 

materials storage areas at an industrial plant (40 CFR 122.26(b)(14)). 

These regulations require that facilities with the following storm water 

discharges apply for a NPDES permit: (1) a discharge associated with 

industrial activity; (2) a discharge from a large or medium municipal 

storm sewer system; or (3) a discharge which EPA or the State determines 

to contribute to a violation of a water quality standard or is a significant 

contributor of pollutants to waters of the United States. 

SIC Code 24 74 September 1995 
Sector Notebook Project Lumber and Wood Products 

The term "storm water discharge associated with industrial activity" 

means a storm water discharge from one of 11 categories of industrial 

activity defined at 40 CFR 122.26. Six of the categories are defined by SIC 

codes while the other five are identified through narrative descriptions of 

the regulated industrial activity. If the primary SIC code of the facility is 

one of those identified in the regulations, the facility is subject to the 

storm water permit application requirements. If any activity at a facility 

is covered by one of the five narrative categories, storm water discharges 

from those areas where the activities occur are subject to storm water 

discharge permit application requirements. 

Those facilities/activities that are subject to storm water discharge permit 

application requirements are identified below. To determine whether a 

particular facility falls within one of these categories, the regulation 

should be consulted. 

Category i: Facilities subject to storm water effluent guidelines, new 

source performance standards, or toxic pollutant effluent standards. 

Category ii: Facilities classified as SIC 24-lumber and wood products 

(except wood kitchen cabinets); SIC 26-paper and allied products (except 

paperboard containers and products); SIC 28-chemicals and allied 

products (except drugs and paints); SIC 29-petroleum refining; and SIC 

311-leather tanning and finishing. 

Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal 

mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral 

mining. 

Category iv: Hazardous waste treatment, storage, or disposal facilities. 

Category v: Landfills, land application sites, and open dumps that 

receive or have received industrial wastes. 

Category vi: Facilities classified as SIC 5015-used motor vehicle parts; 

and SIC 5093-automotive scrap and waste material recycling facilities. 

Category vii: Steam electric power generating facilities. 

Category viii: Facilities classified as SIC 40-railroad transportation; SIC 

41-local passenger transportation; SIC 42-trucking and warehousing 

(except public warehousing and storage); SIC 43-U.S. Postal Service; SIC 

44-water transportation; SIC 45-transportation by air; and SIC 5171-

petroleum bulk storage stations and terminals. 

September 1995 75 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Category ix: Sewage treatment works. 

Category x: Construction activities except operations that result in the 

disturbance of less than five acres of total land area. 

Category xi: Facilities classified as SIC 20-food and kindred products; SIC 

21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related 

products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-

furniture and fixtures; SIC 265-paperboard containers and boxes; SIC 267-

converted paper and paperboard products; SIC 27-printing, publishing, 

and allied industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, 

enamels, and allied products; SIC 30-rubber and plastics; SIC 31-leather 

and leather products (except leather and tanning and finishing); SIC 323-

glass products; SIC 34-fabricated metal products (except fabricated 

structural metal); SIC 35-industrial and commercial machinery and 

computer equipment; SIC 36-electronic and other electrical equipment 

and components; SIC 37-transportation equipment (except ship and boat 

building and repairing); SIC 38-measuring, analyzing, and controlling 

instruments; SIC 39-miscellaneous manufacturing industries; and SIC 

4221-4225-public warehousing and storage. 

Pretreatment Program 

Another type of discharge that is regulated by the CWA is one that goes 

to a publicly-owned treatment works (POTWs). The national 

pretreatment program (CWA §307(b)) controls the indirect discharge of 

pollutants to POTWs by "industrial users." Facilities regulated under 

§307(b) must meet certain pretreatment standards. The goal of the 

pretreatment program is to protect municipal wastewater treatment plants 

from damage that may occur when hazardous, toxic, or other wastes are 

discharged into a sewer system and to protect the quality of sludge 

generated by these plants. Discharges to a POTW are regulated primarily 

by the POTW itself, rather than the State or EPA. 

EPA has developed technology-based standards for industrial users of 

POTWs. Different standards apply to existing and new sources within 

each category. "Categorical" pretreatment standards applicable to an 

industry on a nationwide basis are developed by EPA. In addition, 

another kind of pretreatment standard, "local limits," are developed by 

the POTW in order to assist the POTW in achieving the effluent 

limitations in its NPDES permit. 

SIC Code 24 76 September 1995 
Sector Notebook Project Lumber and Wood Products 

Regardless of whether a State is authorized to implement either the 

NPDES or the pretreatment program, if it develops its own program, it 

may enforce requirements more stringent than Federal standards. 

EPA’s Office of Water, at (202) 260-5700, will direct callers with questions about 

the CWA to the appropriate EPA office. EPA also maintains a bibliographic 

database of Office of Water publications which can be accessed through the 

Ground Water and Drinking Water resource center, at (202) 260-7786. 

Safe Drinking Water Act 

The Safe Drinking Water Act (SDWA) mandates that EPA establish 

regulations to protect human health from contaminants in drinking water. 

The law authorizes EPA to develop national drinking water standards 

and to create a joint Federal-State system to ensure compliance with these 

standards. The SDWA also directs EPA to protect underground sources 

of drinking water through the control of underground injection of liquid 

wastes. 

EPA has developed primary and secondary drinking water standards 

under its SDWA authority. EPA and authorized States enforce the 

primary drinking water standards, which are, contaminant-specific 

concentration limits that apply to certain public drinking water supplies. 

Primary drinking water standards consist of maximum contaminant level 

goals (MCLGs), which are non-enforceable health-based goals, and 

maximum contaminant levels (MCLs), which are enforceable limits set as 

close to MCLGs as possible, considering cost and feasibility of attainment. 

The SDWA Underground Injection Control (UIC) program (40 CFR Parts 

144-148) is a permit program which protects underground sources of 

drinking water by regulating five classes of injection wells. UIC permits 

include design, operating, inspection, and monitoring requirements. 

Wells used to inject hazardous wastes must also comply with RCRA 

corrective action standards in order to be granted a RCRA permit, and 

must meet applicable RCRA land disposal restrictions standards. The 

UIC permit program is primarily State-enforced, since EPA has 

authorized all but a few States to administer the program. 

The SDWA also provides for a Federally-implemented Sole Source 

Aquifer program, which prohibits Federal funds from being expended on 

projects that may contaminate the sole or principal source of drinking 

water for a given area, and for a State-implemented Wellhead Protection 

program, designed to protect drinking water wells and drinking water 

recharge areas. 

September 1995 77 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

EPA’s Safe Drinking Water Hotline, at (800) 426-4791, answers questions and 

distributes guidance pertaining to SDWA standards. The Hotline operates from 

9:00 a.m. through 5:30 p.m., EST, excluding Federal holidays. 

Toxic Substances Control Act 

The Toxic Substances Control Act (TSCA) granted EPA authority to create 

a regulatory framework to collect data on chemicals in order to evaluate, 

assess, mitigate, and control risks which may be posed by their 

manufacture, processing, and use. TSCA provides a variety of control 

methods to prevent chemicals from posing unreasonable risk. 

TSCA standards may apply at any point during a chemical’s life cycle. 

Under TSCA §5, EPA has established an inventory of chemical 

substances. If a chemical is not already on the inventory, and has not 

been excluded by TSCA, a premanufacture notice (PMN) must be 

submitted to EPA prior to manufacture or import. The PMN must 

identify the chemical and provide available information on health and 

environmental effects. If available data are not sufficient to evaluate the 

chemical's effects, EPA can impose restrictions pending the development 

of information on its health and environmental effects. EPA can also 

restrict significant new uses of chemicals based upon factors such as the 

projected volume and use of the chemical. 

Under TSCA §6, EPA can ban the manufacture or distribution in 

commerce, limit the use, require labeling, or place other restrictions on 

chemicals that pose unreasonable risks. Among the chemicals EPA 

regulates under §6 authority are asbestos, chlorofluorocarbons (CFCs), 

and polychlorinated biphenyls (PCBs). 

EPA’s TSCA Assistance Information Service, at (202) 554-1404, answers 

questions and distributes guidance pertaining to Toxic Substances Control Act 

standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST, 

excluding Federal holidays. 

Clean Air Act 

The Clean Air Act (CAA) and its amendments, including the Clean Air 

Act Amendments (CAAA) of 1990, are designed to “protect and enhance 

the nation's air resources so as to promote the public health and welfare 

and the productive capacity of the population.” The CAA consists of six 

sections, known as Titles, which direct EPA to establish national 

standards for ambient air quality and for EPA and the States to 

SIC Code 24 78 September 1995 
Sector Notebook Project Lumber and Wood Products 

implement, maintain, and enforce these standards through a variety of 

mechanisms. Under the CAAA, many facilities will be required to obtain 

permits for the first time. State and local governments oversee, manage, 

and enforce many of the requirements of the CAAA. CAA regulations 

appear at 40 CFR Parts 50-99. 

Pursuant to Title I of the CAA, EPA has established national ambient air 

quality standards (NAAQSs) to limit levels of "criteria pollutants," 

including carbon monoxide, lead, nitrogen dioxide, particulate matter, 

ozone, and sulfur dioxide. Geographic areas that meet NAAQSs for a 

given pollutant are classified as attainment areas; those that do not meet 

NAAQSs are classified as non-attainment areas. Under §110 of the CAA, 

each State must develop a State Implementation Plan (SIP) to identify 

sources of air pollution and to determine what reductions are required to 

meet Federal air quality standards. 

Title I also authorizes EPA to establish New Source Performance 

Standards (NSPSs), which are nationally uniform emission standards for 

new stationary sources falling within particular industrial categories. 

NSPSs are based on the pollution control technology available to that 

category of industrial source but allow the affected industries the 

flexibility to devise a cost-effective means of reducing emissions. 

Under Title I, EPA establishes and enforces National Emission Standards 

for Hazardous Air Pollutants (NESHAPs), nationally uniform standards 

oriented towards controlling particular hazardous air pollutants (HAPs). 

Title III of the CAAA further directed EPA to develop a list of sources that 

emit any of 189 HAPs, and to develop regulations for these categories of 

sources. To date EPA has listed 174 categories and developed a schedule 

for the establishment of emission standards. The emission standards will 

be developed for both new and existing sources based on "maximum 

achievable control technology" (MACT). The MACT is defined as the 

control technology achieving the maximum degree of reduction in the 

emission of the HAPs, taking into account cost and other factors. 

Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, 

and planes. Reformulated gasoline, automobile pollution control devices, 

and vapor recovery nozzles on gas pumps are a few of the mechanisms 

EPA uses to regulate mobile air emission sources. 

Title IV establishes a sulfur dioxide emissions program designed to 

reduce the formation of acid rain. Reduction of sulfur dioxide releases 

will be obtained by granting to certain sources limited emissions 

September 1995 79 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

allowances, which, beginning in 1995, will be set below previous levels of 

sulfur dioxide releases. 

Title V of the CAAA of 1990 created a permit program for all "major 

sources" (and certain other sources) regulated under the CAA. One 

purpose of the operating permit is to include in a single document all air 

emissions requirements that apply to a given facility. States are 

developing the permit programs in accordance with guidance and 

regulations from EPA. Once a State program is approved by EPA, 

permits will be issued and monitored by that State. 

Title VI is intended to protect stratospheric ozone by phasing out the 

manufacture of ozone-depleting chemicals and restrict their use and 

distribution. Production of Class I substances, including 15 kinds of 

chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000, 

while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 

2030. 

EPA's Control Technology Center, at (919) 541-0800, provides general 

assistance and information on CAA standards. The Stratospheric Ozone 

Information Hotline, at (800) 296-1996, provides general information about 

regulations promulgated under Title VI of the CAA, and EPA's EPCRA Hotline, 

at (800) 535-0202, answers questions about accidental release prevention under 

CAA §112(r). In addition, the Technology Transfer Network Bulletin Board 

System (modem access (919) 541-5742)) includes recent CAA rules, EPA 

guidance documents, and updates of EPA activities. 

VI.B. Industry Specific Requirements 

Clean Air Act (CAA) 

Under the Clean Air Act, PM10, (particulate matter with an aerodynamic 

diameter of 10 microns or less) and volatile organic compounds (VOCs) 

are regulated to ensure attainment with the National Ambient Air Quality 

Standards for PM10 and ground level ozone (VOCs contribute to the 

formation of ground level ozone). Wood products have the potential to 

emit PM10 and VOCs in significant quantities. 

As required by §110 of the CAA, State Implementation Plans (SIPs) must 

be developed to identify sources of air pollution and determine what 

reductions are required to meet Federal standards. An important 

compliance component of these SIPs are generic opacity limits, which 

dictate that no stack shall have emissions above a certain percent opacity. 

SIC Code 24 80 September 1995 
Sector Notebook Project Lumber and Wood Products 

Within the wood products industry, these regulations apply to hog fuel 

boilers and veneer dryers. The standard limit for emissions of all kinds is 

20 percent opacity, meaning that only 80 percent of light is able to pass 

through the plume. However, some States provide exceptions to the 

opacity limits for certain industries or manufacturing processes 

depending on the state's SIP. 

Also written into each SIP are provisions that require all new stationary 

sources constructed in a National Ambient Air Quality Standards 

(NAAQ) attainment area and that have the potential to emit above a 

specified tonnage per year to install best available control technology 

(BACT). In addition, these facilities need to obtain a Prevention of 

Significant Deterioration (PSD) permit (40 CFR 52.21). 

Standards of Performance for Fossil Fuel Fired Steam Generating Units 

(40 CFR 60.40, subpart D), apply to any fossil fuel-fired and wood residue 

fired steam generating unit that commences construction modification or 

reconstruction after August 17, 1971, and that has a heat input capacity 

derived from fossil fuels of greater than 73 megawatts (250 mm BTU/hr). 

Unlike subparts Db and Dc, descriptions of which follow, the contribution 

of heat from wood fuels is not considered in determining the heat input 

capacity since it is not a fossil fuel. The regulation addresses emission 

standards, compliance and performance test methods, monitoring 

requirements (including continuous opacity monitoring systems), and 

reporting requirements for particulate matter, nitrogen oxides, and sulfur 

dioxide. 

Standards of Performance for Industrial-Commercial-Institutional Steam 

Generating Units (40 CFR 60.40b, subpart Db), apply to any steam 

generating unit that commences construction, modification, or 

reconstruction after June 19, 1984 and that has a heat input (heat derived 

from combustion of fuel only, not exhaust gases, etc.) capacity of at least 

29 MW. This includes steam generating units that use wood as a source 

of fuel. The regulation addresses emission standards, compliance and 

performance test methods, monitoring requirements, and reporting 

requirements for particulate matter, nitrogen oxides, and sulfur dioxide. 

Standards of Performance for Small Industrial-Commercial-Institutional 

Steam Generating Units (40 CFR 60.40c, Subpart Dc), apply to any small 

steam generating unit (2.9 MW to 29 MW) that commences construction, 

modification, or reconstruction, after June 9, 1989. The regulation 

addresses requirements for particulate matter and sulfur dioxide 

emissions. 

September 1995 81 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

In addition to applying to steam generating units in general (including 

wood-fueled plants), the subparts make several specific references to 

wood-fueled plants. With regard to small units, the regulation provides: 

• A formula for allowable sulfur dioxide emissions (based on the 

amount of fuel used) that excludes wood from the calculation of 

fuel used 

• Particulate matter standards for facilities that combust wood 

• Opacity standards for facilities that combust wood 

• Nitrogen oxide standards for facilities that combust combinations 

of wood and other fuels 

• Compliance procedures for facilities that combust combinations of 

wood and other fuels. 

Clean Water Act (CWA) 

Facilities in the lumber and wood products industry that discharge 

treated wastewaters from point sources to surface waters of the U.S. must 

obtain a National Pollutant Discharge Elimination System (NPDES) 

permit. The NPDES permit program is authorized by Section 402 of the 

CWA and is implemented through 40 CFR Parts 122 through 124. Other 

parts of the CFR affecting the NPDES program include Part 125 

(technology-based standards), Part 129 (toxic pollutant standards), and 

Part 130 (water quality-based standards). Discharges to publicly-owned 

treatment works (POTWs) are subject to the pretreatment standards in 40 

CFR Part 403. 

Technology-based permit limits are derived from effluent limitation 

guidelines and standards (ELG); 40 CFR Part 429 for this industry. These 

limitations incorporate both technology-based and water quality-based 

limits, depending on which is more protective. Effluent guidelines 

subdivide the industry based on the following production operations: 

• Veneer 

• Plywood 

• Dry process hardboard 

• Wet process hardboard 

• Wood preserving—water-borne or nonpressure 

• Wood preserving—steam 

• Wood preserving—Boulton. 

SIC Code 24 82 September 1995 
Sector Notebook Project Lumber and Wood Products 

The guidelines set limitations for the pollutants of concern (i.e., BOD5, 

TSS, pH, COD, phenols, and oil and grease for those facilities in the wood 

preserving subcategory). 

Resource Conservation and Recovery Act (RCRA) 

Wood Preserving Final Rule 

EPA amended regulations under RCRA (57 Federal Register 61502, 

December 30, 1992) by listing as hazardous three categories of wastes 

generated by wood preserving operations that use chlorophenolic, 

creosote, and/or inorganic (arsenical and chromium) preservatives. 

The listed wastes include wastewaters, process residuals, preservative 

drippage, and spent preservatives from wood preserving processes at 

facilities that use or have previously used chlorophenolic formulations, 

facilities that use creosote formulations, and facilities that use inorganic 

preservatives containing arsenic or chromium. 

Specifically, the following RCRA-regulated hazardous wastes are related 

to wood preserving operations: 

• K001 (bottom sediment sludge from the treatment of wastewaters 

from wood preserving processes that use creosote or PCP), 

• F032 (wastewaters, process residuals, preservative drippage, and 

spent formulations from wood preserving processes generated at 

plants that currently use or have previously used chlorophenolic 

formulations), 

• F034 (wastewaters, process residuals, preservative drippage, and 

spent formulations from wood preserving processes generated at 

plants that use creosote formulations), and 

• F035 (wastewaters, process residuals, preservative drippage, and 

spent formulations from wood preserving processes generated at 

plants that use inorganic preservatives containing arsenic or 

chromium). 

The rule includes permitting and interim status standards for the drip 

pads used to assist in the collection of treated wood drippage. These 

standards include requirements for drip pad design, operation, 

inspection, and closure. 

September 1995 83 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), of 1947 

(7 U.S.C. 136) requires registration of pesticides to protect consumers from 

mislabeled, defective, and ineffective pesticides and to identify products 

that might be harmful to public health or the environment even when 

used properly. FIFRA has been amended several times: in 1972, 1975, 

1978, 1980, 1988, and 1991. The primary purpose of the 1972 amendments 

was to ensure that pesticide use would be subject to a thorough review of 

environmental and human health hazards. The 1988 amendments 

established schedules and duties for re-registration of pesticides. 

Under FIFRA, a registered pesticide must be used in a manner consistent 

with its label. A registered pesticide may be used in a manner 

inconsistent with its label in the following situations, unless specifically 

prohibited by the label: 

• Applying a pesticide at a dosage, concentration, or frequency less 

than that specified on the label 

• Applying a pesticide against a pest not specified on the label if the 

application is to a crop, animal, or site that is specified on the label 

• Employing a method of application not specifically prohibited by 

the label 

• Mixing a pesticide with a fertilizer 

• Applying a pesticide in conformance with an experimental use 

permit, or a specific exemption of a Federal or State agency 

• Applying a pesticide in a manner that the Administrator 

determines is consistent with the purposes of FIFRA. 

Use of a registered pesticide in a manner inconsistent with its label is 

unlawful in all other situations. 

In addition, the Administrator has the authority to classify pesticides as 

being for general use or for restricted use only. Pesticides classified as for 

restricted use only include creosote, pentachlorophenol, and inorganic 

salts such as chromated copper arsenate, all of which are used in woodpreserving solutions. Such pesticides must be applied only by a certified 

applicator or under the direct supervision of a certified applicator (section 

136j(a)(1)(F)). Standards for certification are established by the Federal 

government or by State governments with Federal approval. 

SIC Code 24 84 September 1995 
Sector Notebook Project Lumber and Wood Products 

In a notice published in the Federal Register on January 10, 1986 (Vol. 51, 

No. 7, January 10, 1986, p. 1334-1348), the EPA established several 

conditions for registering creosote, pentachlorophenol, and inorganic 

arsenicals for use in wood preserving, to ensure that such use would not 

endanger human health standards. EPA and the wood preserving 

industry agreed that the industry would establish a voluntary Consumer 

Awareness Program to educate consumers in the proper use of and 

precautionary practices regarding wood treated with creosote, 

pentachlorophenol, and inorganic arsenicals, to ensure that such uses 

would not endanger health standards. Through the program, information 

about treated wood is disseminated in an information sheet provided to 

end-users at the time of sale or delivery. An earlier Federal Register 

notice of July 13, 1984 established terms of registration under which the 

wood preserving industry agreed to establish air monitoring systems at 

facilities using formulations containing arsenic. 

VI.C. Pending and Proposed Regulatory Requirements 

RCRA 

As part of EPA’s groundwater protection strategy, RCRA prohibits the 

land disposal of most hazardous wastes until they meet a waste specific 

treatment standard. While most hazardous wastes have already been 

assigned treatment standards, EPA must still promulgate two additional 

rule makings to address newly listed wastes and to make changes to the 

land disposal restrictions (LDR) program. 

When finalized, the Phase III LDR rulemaking will establish treatment 

standards for some newly listed wastes and will mandate RCRA 

equivalent treatment be performed upon certain characteristically 

hazardous wastes that are injected into UIC wells under the Safe Drinking 

Water Act (SDWA) or managed in Subtitle D surface impoundments prior 

to discharge pursuant to the Clean Water Act (CWA). By consent decree, 

EPA must promulgate the final rule for Phase III by January 1996. 

Phase IV will similarly restrict other newly listed or identified wastes 

from land disposal and create influent treatment standards to mitigate the 

impact of sludges, leaks, and air emissions from surface impoundments 

that manage decharacterized wastes. Of particular significance to wood 

preserving industries, Phase IV will restrict the land disposal of F032, 

F034, and F035. Once the prohibitions for these wastes become effective, 

they will need to meet numeric treatment levels for specific hazardous 

constituents commonly found in F032, F034, and F035. Phase IV will also 

restrict the land disposal of the previously exempt Bevill wastes and 

adjust the treatment standards applicable to wastes that exhibit the 

September 1995 85 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

toxicity characteristic for a metal constituent. Subject to the same consent 

decree, Phase IV has been assigned a final judicial deadline of June 1996. 

Clean Air Act 

Many of the chemicals used for wood preserving are listed as hazardous 

air pollutants (HAPs) in Section 112 of the Clean Air Act Amendments of 

1990. Treatment processes have been identified as potentially significant 

sources of these HAPs and, as such, are source categories for which 

national emission standards may be necessary. 

Three emissions standards based on "maximum achievable control 

technology" (MACT) will be developed for products covered by SIC 24: a 

wood treatment MACT standard is due by November 15, 1997; a 

plywood/PB manufacturing MACT standard is due by November 15, 

2000; and a flat wood paneling (surface coating) MACT standard is due 

by November 15, 2000. The MACT is defined as the control technology 

achieving the maximum degree of reduction in the emission of the HAPs, 

taking into account cost and other factors. 

SIC Code 24 86 September 1995 
Sector Notebook Project Lumber and Wood Products 

VII. COMPLIANCE AND ENFORCEMENT HISTORY 

Background 

To date, EPA has focused much of its attention on measuring compliance 

with specific environmental statutes. This approach allows the Agency to 

track compliance with the Clean Air Act, the Resource Conservation and 

Recovery Act, the Clean Water Act, and other environmental statutes. 

Within the last several years, the Agency has begun to supplement singlemedia compliance indicators with facility-specific, multimedia indicators 

of compliance. In doing so, EPA is in a better position to track compliance 

with all statutes at the facility level, and within specific industrial sectors. 

A major step in building the capacity to compile multimedia data for 

industrial sectors was the creation of EPA's Integrated Data for 

Enforcement Analysis (IDEA) system. IDEA has the capacity to "read 

into" the Agency's single-media databases, extract compliance records, 

and match the records to individual facilities. The IDEA system can 

match Air, Water, Waste, Toxics/Pesticides/EPCRA, TRI, and 

Enforcement Docket records for a given facility, and generate a list of 

historical permit, inspection, and enforcement activity. IDEA also has the 

capability to analyze data by geographic area and corporate holder. As 

the capacity to generate multimedia compliance data improves, EPA will 

make available more in-depth compliance and enforcement information. 

Additionally, sector-specific measures of success for compliance 

assistance efforts are under development. 

Compliance and Enforcement Profile Description 

Using inspection, violation, and enforcement data from the IDEA system, 

this section provides information regarding the historical compliance and 

enforcement activity of this sector. In order to mirror the facility universe 

reported in the Toxic Chemical Profile, the data reported within this 

section consists of records only from the TRI reporting universe. With 

this decision, the selection criteria are consistent across sectors with 

certain exceptions. For the sectors that do not normally report to the TRI 

program, data have been provided from EPA's Facility Indexing System 

(FINDS) which tracks facilities in all media databases. Please note, in this 

section, EPA does not attempt to define the actual number of facilities that 

fall within each sector. Instead, the section portrays the records of a 

subset of facilities within the sector that are well defined within EPA 

databases. 

September 1995 87 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

As a check on the relative size of the full sector universe, most notebooks 

contain an estimated number of facilities within the sector according to 

the Bureau of Census (See Section II). With sectors dominated by small 

businesses, such as metal finishers and printers, the reporting universe 

within the EPA databases may be small in comparison to Census data. 

However, the group selected for inclusion in this data analysis section 

should be consistent with this sector's general make-up. 

Following this introduction is a list defining each data column presented 

within this section. These values represent a retrospective summary of 

inspections and enforcement actions, and solely reflect EPA, State, and 

local compliance assurance activities that have been entered into EPA 

databases. To identify any changes in trends, the EPA ran two data 

queries, one for the past five calendar years (August 10, 1990 to August 9, 

1995) and the other for the most recent twelve-month period (August 10, 

1994 to August 9, 1995). The five-year analysis gives an average level of 

activity for that period for comparison to the more recent activity. 

Because most inspections focus on single-media requirements, the data 

queries presented in this section are taken from single media databases. 

These databases do not provide data on whether inspections are 

State/local or EPA-led. However, the table breaking down the universe 

of violations does give the reader a crude measurement of the EPA's and 

States' efforts within each media program. The presented data illustrate 

the variations across regions for certain sectors.2 This variation may be 

attributable to State/local data entry variations, specific geographic 

concentrations, proximity to population centers, sensitive ecosystems, 

highly toxic chemicals used in production, or historical noncompliance. 

Hence, the exhibited data do not rank regional performance or necessarily 

reflect which regions may have the most compliance problems. 

Compliance and Enforcement Data Definitions 

General Definitions 

Facility Indexing System (FINDS) -- this system assigns a common 

facility number to EPA single-media permit records. The FINDS 

identification number allows EPA to compile and review all permit, 

2 EPA Regions include the following States: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); 

III (DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, 

WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX 

(AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA). 

SIC Code 24 88 September 1995 
--

Sector Notebook Project Lumber and Wood Products 

compliance, enforcement, and pollutant release data for any given 

regulated facility. 

Integrated Data for Enforcement Analysis (IDEA) -- is a data integration 

system that can retrieve information from the major EPA program office 

databases. IDEA uses the FINDS identification number to "glue together” 

separate data records from EPA’s databases. This is done to create a 

"master list” of data records for any given facility. Some of the data 

systems accessible through IDEA are: AIRS (Air Facility Indexing and 

Retrieval System, Office of Air and Radiation), PCS (Permit Compliance 

System, Office of Water), RCRIS (Resource Conservation and Recovery 

Information System, Office of Solid Waste), NCDB (National Compliance 

Data Base, Office of Prevention, Pesticides, and Toxic Substances), 

CERCLIS (Comprehensive Environmental and Liability Information 

System, Superfund), and TRIS (Toxic Release Inventory System). IDEA 

also contains information from outside sources such as Dun and 

Bradstreet and the Occupational Safety and Health Administration 

(OSHA). Most data queries displayed in notebook Sections IV and VII 

were conducted using IDEA. 

Data Table Column Heading Definitions 

Facilities in Search -- are based on the universe of TRI reporters within 

the listed SIC code range. For industries not covered under TRI reporting 

requirements, the notebook uses the FINDS universe for executing data 

queries. The SIC code range selected for each search is defined by each 

notebook's selected SIC code coverage described in Section II. 

Facilities Inspected --- indicates the level of EPA and State agency facility 

inspections for the facilities in this data search. These values show what 

percentage of the facility universe is inspected in a 12 or 60 month period. 

This column does not count non-inspectional compliance activities such as 

the review of facility-reported discharge reports. 

Number of Inspections measures the total number of inspections 

conducted in this sector. An inspection event is counted each time it is 

entered into a single media database. 

Average Time Between Inspections -- provides an average length of 

time, expressed in months, that a compliance inspection occurs at a 

facility within the defined universe. 

Facilities with One or More Enforcement Actions -- expresses the 

number of facilities that were party to at least one enforcement action 

September 1995 89 SIC Code 24 
--

--

Lumber and Wood Products Sector Notebook Project 

within the defined time period. This category is broken down further 

into Federal and State actions. Data are obtained for administrative, 

civil/judicial, and criminal enforcement actions. Administrative actions 

include Notices of Violation (NOVs). A facility with multiple 

enforcement actions is only counted once in this column (facility with 3 

enforcement actions counts as 1). All percentages that appear are 

referenced to the number of facilities inspected. 

Total Enforcement Actions -- describes the total number of enforcement 

actions identified for an industrial sector across all environmental 

statutes. A facility with multiple enforcement actions is counted multiple 

times (a facility with 3 enforcement actions counts as 3). 

State Lead Actions shows what percentage of the total enforcement 

actions are taken by State and local environmental agencies. Varying 

levels of use by States of EPA data systems may limit the volume of 

actions accorded State enforcement activity. Some States extensively 

report enforcement activities into EPA data systems, while other States 

may use their own data systems. 

Federal Lead Actions shows what percentage of the total enforcement 

actions are taken by the U.S. EPA. This value includes referrals from State 

agencies. Many of these actions result from coordinated or joint 

State/Federal efforts. 

Enforcement to Inspection Rate -- expresses how often enforcement 

actions result from inspections. This value is a ratio of enforcement 

actions to inspections, and is presented for comparative purposes only. 

This measure is a rough indicator of the relationship between inspections 

and enforcement. This measure simply indicates historically how many 

enforcement actions can be attributed to inspection activity. Related 

inspections and enforcement actions under the Clean Water Act (PCS), the 

Clean Air Act (AFS) and the Resource Conservation and Recovery Act 

(RCRA) are included in this ratio. Inspections and actions from the 

TSCA/FIFRA/EPCRA database are not factored into this ratio because 

most of the actions taken under these programs are not the result of 

facility inspections. This ratio does not account for enforcement actions 

arising from non-inspection compliance monitoring activities (e.g., selfreported water discharges) that can result in enforcement action within 

the CAA, CWA and RCRA. 

Facilities with One or More Violations Identified -- indicates the 

number and percentage of inspected facilities having a violation 

identified in one of the following data categories: In Violation or 

SIC Code 24 90 September 1995 
Sector Notebook Project Lumber and Wood Products 

Significant Violation Status (CAA); Reportable Noncompliance, Current 

Year Noncompliance, Significant Noncompliance (CWA); Noncompliance 

and Significant Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved 

Violation and Unresolved High Priority Violation (RCRA). The values 

presented for this column reflect the extent of noncompliance within the 

measured time frame, but do not distinguish between the severity of the 

noncompliance. Percentages within this column can exceed 100 percent 

because facilities can be in violation status without being inspected. 

Violation status may be a precursor to an enforcement action, but does not 

necessarily indicate that an enforcement action will occur. 

Media Breakdown of Enforcement Actions and Inspections -- four 

columns identify the proportion of total inspections and enforcement 

actions within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA 

databases. Each column is a percentage of either the "Total Inspections,” 

or the "Total Actions” column. 

VII.A. Lumber and Wood Products Industry Compliance History 

Exhibit 23 provides a Regional breakdown of the five-year enforcement 

and compliance activities for the lumber and wood products industry. 

Region IV conducted almost 50 percent of the inspections of lumber and 

wood product manufacturing facilities performed in the U.S. This large 

percentage is due to the concentration of lumber and wood product 

manufacturers in the Southeastern U.S. The exhibit also indicates that 100 

percent of the enforcement actions in Regions II and VII were lead by the 

State while 100 percent of the enforcement actions in Region VIII were 

lead by EPA. 

September 1995 91 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 23

Five Year Enforcement and Compliance Summary for the Lumber and Wood

Industry

A B C D E F G H I J 

Lumber and Wood 

SIC 24 

Facilities in 

Search 

Facilities 

Inspected 

Number of 

Inspections 

Average 

Number of 

Months 

Between 

Inspections 

Facilities 

w/one or 

more 

Enforcement 

Actions 

Total 

Enforcement 

Actions State Lead 

Actions 

Federal Lead 

Actions 

Enforcement 

to Inspection 

Rate 

Region I 11 9 29 24 4 3 0% 100% 0.10 

Region II 13 11 49 17 1 6 100% 0% 0.12 

Region III 60 40 276 14 11 25 88% 12% 0.09 

Region IV 189 123 1,072 11 40 105 88% 12% 0.10 

Region V 74 44 203 23 14 29 59% 41% 0.14 

Region VI 67 39 239 18 23 59 80% 20% 0.25 

Region VII 5 4 31 10 2 2 100% 0% 0.06 

Region VIII 12 6 32 24 2 0 0% 0% 0 

Region IX 26 20 126 13 9 19 58% 42% 0.15 

Region X 37 27 120 19 7 10 60% 40% 0.08 

Total/Average 494 323 2,177 14 113 258 79% 21% 0.12 

SIC Code 24 92 September 1995 
Sector Notebook Project Lumber and Wood Products 

VII.B. Comparison of Enforcement Activity Between Selected Industries 

Exhibits 24-27 contain summaries of the one and five year enforcement 

and compliance activities for the lumber and wood products industry, as 

well as for other selected industries. As indicated in Exhibits 24 and 25, 

the lumber and wood products industry has an average enforcement to 

inspection rate compared to other industries. Exhibits 26 and 27 provide 

a breakdown of inspection and enforcement activities by statute. Of all 

inspections of lumber and wood products industry facilities, 

approximately 59 percent were performed under the Resource 

Conservation and Recovery Act, while approximately 31 percent were 

conducted under the Clean Air Act. The large percentages of RCRA and 

CAA inspections for this industry are due in part to facility construction 

requirements for wood preserving facilities under RCRA, and emissions 

standards under CAA. 

September 1995 93 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 24

Five Year Enforcement and Compliance Summary for Selected Industries

A B C D E F G H I J 

Industry Sector Facilities in 

Search 

Facilities 

Inspected 

Number 

of 

Inspection 

s 

Average 

Number of 

Months 

Between 

Inspections 

Facilities 

w/One or 

More 

Enforcement 

Actions 

Total 

Enforceme 

nt Actions 

State 

Lead 

Actions 

Federal 

Lead 

Actions 

Enforcement 

to Inspection 

Rate 

Metal Mining 873 339 1,519 34 67 155 47% 53% 0.10 

Non-metallic 

Mineral Mining 

1,143 631 3,422 20 84 192 76% 24% 0.06 

Lumber and Wood 464 301 1,891 15 78 232 79% 21% 0.12 

Furniture 293 213 1,534 11 34 91 91% 9% 0.06 

Rubber and Plastic 1,665 739 3,386 30 146 391 78% 22% 0.12 

Stone, Clay, and 

Glass 

468 268 2,475 11 73 301 70% 30% 0.12 

Nonferrous Metals 844 474 3,097 16 145 470 76% 24% 0.15 

Fabricated Metal 2,346 1,340 5,509 26 280 840 80% 20% 0.15 

Electronics/Comput 

ers 

405 222 777 31 68 212 79% 21% 0.27 

Motor Vehicle 

Assembly 

598 390 2,216 16 81 240 80% 20% 0.11 

Pulp and Paper 306 265 3,766 5 115 502 78% 22% 0.13 

Printing 4,106 1,035 4,723 52 176 514 85% 15% 0.11 

Inorganic Chemicals 548 298 3,034 11 99 402 76% 24% 0.13 

Organic Chemicals 412 316 3,864 6 152 726 66% 34% 0.19 

Petroleum Refining 156 145 3,257 3 110 797 66% 34% 0.25 

Iron and Steel 374 275 3,555 6 115 499 72% 28% 0.14 

Dry Cleaning 933 245 633 88 29 103 99% 1% 0.16 

SIC Code 24 94 September 1995
Sector Notebook Project Lumber and Wood Products 

Exhibit 25

One Year Enforcement and Compliance Summary for Selected Industries

A C D E F G H 

Industry Sector Facilities 

in Search 

Facilities 

Inspected 

Number 

of 

Inspection 

s 

Facilities w/One or 

More Violations 

Facilities w/One or More 

Enforcement Actions 

Total 

Enforcement 

Actions 

Enforceme 

nt to 

Inspection 

Rate 

Number Percent* Number Percent* 

Metal Mining 873 114 194 82 72% 16 14% 24 0.13 

Non-metallic Mineral 

Mining 

1,143 253 425 75 30% 28 11% 54 0.13 

Lumber and Wood 464 142 268 109 77% 18 13% 42 0.15 

Furniture 293 160 113 66 41% 3 2% 5 0.04 

Rubber and Plastic 1,665 271 435 289 107% 19 7% 59 0.14 

Stone, Clay, and 

Glass 

468 146 330 116 79% 20 14% 66 0.20 

Nonferrous Metals 844 202 402 282 140% 22 11% 72 0.18 

Fabricated Metal 2,346 477 746 525 110% 46 10% 114 0.15 

Electronics/Compute 

rs 

405 60 87 80 133% 8 13% 21 0.24 

Motor Vehicle 

Assembly 

598 169 284 162 96% 14 8% 28 0.10 

Pulp and Paper 306 189 576 162 86% 28 15% 88 0.15 

Printing 4,106 397 676 251 63% 25 6% 72 0.11 

Inorganic Chemicals 548 158 427 167 106% 19 12% 49 0.12 

Organic Chemicals 412 195 545 197 101% 39 20% 118 0.22 

Petroleum Refining 156 109 437 109 100% 39 36% 114 0.26 

Iron and Steel 374 167 488 165 99% 20 12% 46 0.09 

Dry Cleaning 933 80 111 21 26% 5 6% 11 0.10 

*Percentages in Columns E and F are based on the number of facilities inspected (Column C). Percentages can exceed 100% because violations and 

actions can occur without a facility inspection. 

B 

September 1995 95 SIC Code 24
Lumber and Wood Products Sector Notebook Project

SIC Code 24 96 September 1995

Exhibit 26

Five Year Inspection and Enforcement Summary by Statute for Selected Industries

Industry Sector Number

of

Facilities

Inspected

Total

Inspection

s

Enforceme

nt Actions

Clean Air Act Clean Water Act Resource Conservation

and Recovery Act

FIFRA/TSCA/

EPCRA/Other

*

% of Total

Inspection

s

% of Total

Actions

% of Total

Inspection

s

% of Total

Actions

% of Total

Inspection

s

% of Total

Actions

% of Total

Inspection

s

% of Total

Actions

Metal Mining 339 1,519 155 35% 17% 57% 60% 6% 14% 1% 9%

Non-metallic

Mineral Mining

631 3,422 192 65% 46% 31% 24% 3% 27% <1% 4%

Lumber and

Wood

301 1,891 232 31% 21% 8% 7% 59% 67% 2% 5%

Furniture 293 1,534 91 52% 27% 1% 1% 45% 64% 1% 8%

Rubber and

Plastic

739 3,386 391 39% 15% 13% 7% 44% 68% 3% 10%

Stone, Clay and

Glass

268 2,475 301 45% 39% 15% 5% 39% 51% 2% 5%

Nonferrous

Metals

474 3,097 470 36% 22% 22% 13% 38% 54% 4% 10%

Fabricated

Metal

1,340 5,509 840 25% 11% 15% 6% 56% 76% 4% 7%

Electronics/

Computers

222 777 212 16% 2% 14% 3% 66% 90% 3% 5%

Motor Vehicle

Assembly

390 2,216 240 35% 15% 9% 4% 54% 75% 2% 6%

Pulp and Paper 265 3,766 502 51% 48% 38% 30% 9% 18% 2% 3%

Printing 1,035 4,723 514 49% 31% 6% 3% 43% 62% 2% 4%

Inorganic

Chemicals

302 3,034 402 29% 26% 29% 17% 39% 53% 3% 4%

Organic

Chemicals

316 3,864 726 33% 30% 16% 21% 46% 44% 5% 5%

Petroleum

Refining

145 3,237 797 44% 32% 19% 12% 35% 52% 2% 5%

Iron and Steel 275 3,555 499 32% 20% 30% 18% 37% 58% 2% 5%

Dry Cleaning 245 633 103 15% 1% 3% 4% 83% 93% <1% 1%

* Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act; the Toxic Substances

and Control Act, and the Emergency Planning and Community Right-to-Know Act as well as other

Federal environmental laws.
Sector Notebook Project Lumber and Wood Products

September 1995 97 SIC Code 24

Exhibit 27

One Year Inspection and Enforcement Summary by Statute for Selected Industries

Industry

Sector

Number

of

Facilities

Inspected

Total

Inspection

s

Enforceme

nt Actions

Clean Air Act Clean Water Act Resource Conservation

and Recovery Act

FIFRA/TSCA/

EPCRA/Other

% of Total

Inspection

s

% of

Total

Actions

% of Total

Inspection

s

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspection

s

% of

Total

Actions

Metal Mining 114 194 24 47% 42% 43% 34% 10% 6% <1% 19%

Non-metallic

Mineral

Mining

253 425 54 69% 58% 26% 16% 5% 16% <1% 11%

Lumber and

Wood

142 268 42 29% 20% 8% 13% 63% 61% <1% 6%

Furniture 293 160 5 58% 67% 1% 10% 41% 10% <1% 13%

Rubber and

Plastic

271 435 59 39% 14% 14% 4% 46% 71% 1% 11%

Stone, Clay,

and Glass

146 330 66 45% 52% 18% 8% 38% 37% <1% 3%

Nonferrous

Metals

202 402 72 33% 24% 21% 3% 44% 69% 1% 4%

Fabricated

Metal

477 746 114 25% 14% 14% 8% 61% 77% <1% 2%

Electronics/

Computers

60 87 21 17% 2% 14% 7% 69% 87% <1% 4%

Motor Vehicle

Assembly

169 284 28 34% 16% 10% 9% 56% 69% 1% 6%

Pulp and

Paper

189 576 88 56% 69% 35% 21% 10% 7% <1% 3%

Printing 397 676 72 50% 27% 5% 3% 44% 66% <1% 4%

Inorganic

Chemicals

158 427 49 26% 38% 29% 21% 45% 36% <1% 6%

Organic

Chemicals

195 545 118 36% 34% 13% 16% 50% 49% 1% 1%

Petroleum

Refining

109 439 114 50% 31% 19% 16% 30% 47% 1% 6%

Iron and Steel 167 488 46 29% 18% 35% 26% 36% 50% <1% 6%

Dry Cleaning 80 111 11 21% 4% 1% 22% 78% 67% <1% 7%

* Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act; the

Toxic Substances and Control Act, and the Emergency Planning

and Community Right-to-Know Act as well as other Federal environmental laws.
Lumber and Wood Products Sector Notebook Project 

VII.C. Review of Major Legal Actions 

VII.C.1. Review of Major Cases 

This section provides summary information about major cases that have 

affected this sector. As indicated in EPA’s Enforcement Accomplishments 

Report, FY 1991, FY 1992, FY 1993 publications, nine significant 

enforcement cases were resolved between 1991 and 1993 for the lumber 

and wood products industry. CAA violations comprised four of these 

cases, the most of any statute. The remaining cases were distributed fairly 

evenly, with CERCLA cited twice, RCRA cited twice, and FIFRA cited 

once. 

Three of the CAA violations involved excessive hog fuel (waste wood) 

boiler emissions. Each of these settlements include Supplemental 

Environmental Projects (SEPs), such as the installation of boiler 

precipitators, and penalties were usually under $100,000. A notable 

exception, however, is U.S. v. Louisiana-Pacific Corporation and Kirby Forest 

Industries (1993). The case involved numerous violations of State 

Implementation Plans, Prevention of Significant Deterioration 

requirements, New Source Review requirements, and State permit 

requirements at its Louisiana-Pacific facilities. The penalty assessed in 

this case represents the largest CAA civil penalty ever collected by EPA, 

and the second largest penalty recovered under any environmental 

statute. Under the terms of a consent decree, Louisiana-Pacific was 

required to pay $11.1 million in civil penalties and was required to install 

state-of-the-art pollution control equipment valued at $70 million. 

The remaining enforcement actions (under CERCLA, RCRA, and FIFRA) 

involved sites with contamination caused by wood treatment processes. 

Penalties assessed against responsible parties at these sites ranged from 

$68,000 to $350,000. In addition, a CERCLA settlement at the Koppers 

NPL site required Beazer East, Inc. to perform design, construction, 

operation, and maintenance of an operable unit valued at approximately 

$77 million. 

SIC Code 24 98 September 1995 
Sector Notebook Project Lumber and Wood Products 

VII.C.2. Supplemental Environmental Projects (SEPs) 

Supplementary Environmental Projects (SEPs) are compliance agreements 

that reduce a facility's stipulated penalty in return for an environmental 

project that exceeds the value of the reduction. Often, these projects fund 

pollution prevention activities that can significantly reduce the future 

pollutant loadings of a facility. 

In December, 1993, the Regions were asked by EPA's Office of 

Enforcement to provide information on the number and type of SEPs 

entered into by the Regions. Exhibit 28 contains a representative sample 

of the Regional responses addressing the lumber and wood products 

industry. The information contained in the chart is not comprehensive 

and provides only a sample of the types of SEPs developed for the lumber 

and wood products industry. 

September 1995 99 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Exhibit 28

Supplemental Environmental Projects

Case Name EPA 

Region 

Statute/ 

Type of 

Action 

Type of 

SEP 

Estimate 

d Cost to 

Company 

Expected Environmental Benefits Final 

Assesse 

d 

Penalty 

Final 

Penalty 

After 

Mitigation 

Louisiana-Pacific 

Corporation 

Moyie Springs, ID 

10 CAASIP Pollution 

Reduction 

$ 102,950 Installation of electrified filter bed to reduce 

particulate emissions. 

$ 67,972 $ 33,986 

Merritt Brothers 

Lumber Company 

Priest River, ID 

10 CAASIP Pollution 

Reduction 

$ 213,881 Installation of electrostatic precipitator to reduce 

particualte emissions. 

$ 20,208 $ 10,104 

Rosboro Lumber 

Company 

Springfield, OR 

10 TSCA Pollution 

Reduction 

$ 37,230 Early disposal of PCB and PCB-contaminated 

electrical equipment. 

$ 37,230 $ 18,615 

JD Lumber, Inc. 

Priest River, ID 

10 CAASIP Pollution 

Preventio 

n 

$ 58,000 Purchase and installation of "hog" machine to 

reduce particulate emissions. 

$ 17,500 $ 8,750 

Riley Creek Lumber 

Company 

Laclede, ID 

10 CAASIP Pollution 

Reduction 

$ 254,000 Purchase and installation of electrostatic 

precipitator to reduce particulate emissions. 

$ 20,000 $ 10,000 

Georgia Pacific 

Zachary, LA 

6 CERCL 

A 

Equipmen 

t 

Donation 

$ 6,000 Donate emergency and/or computer equipment 

to the Local Emergency Planning Committee 

(LEPC) to respond to and/or plan for chemical 

emergencies. Participate in LEPC activities. 

$ 25,000 $ 5,000 

SIC Code 24 100 September 1995
Sector Notebook Project Lumber and Wood Products 

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 

This section highlights the activities undertaken by this industry sector 

and public agencies to voluntarily improve the sector's environmental 

performance. These activities include those independently initiated by 

industrial trade associations. In this section, the notebook also contains a 

listing and description of national and regional trade associations. 

VIII.A. Sector-Related Environmental Programs and Initiatives 

EPA Region X conducted the "Idaho Rule Effectiveness Study" from 

March 1991 through October 1992 in the Idaho Panhandle. The study 

focused on sources of PM and was designed to evaluate the effectiveness 

of Idaho rules regulating particulate emissions: the sources selected for 

the study, which included many wood products facilities, were located in 

or near suspected PM10 non-attainment areas. Inspections evaluated the 

compliance status of 26 sources with respect to Idaho rules concerning 

emissions limitations, visible emissions limitations for wigwam burners, 

permits to construct, operating permits, and particulate standards for 

combustion sources. 

EPA's impression following completion of the study was that existing 

controls were not adequate to comply with applicable regulations. A 

majority of sources used multiclones as their primary control device. 

Equipment was not routinely maintained; sources did not appear to have 

a routine operation and maintenance program (O&M); and many mill 

managers had little knowledge of the air quality regulations that applied 

to their facility. 

A second conclusion reached by EPA was that environmental 

responsibilities were secondary to those related to the operation of the 

mill. Even at the largest facilities, the manager of the mill was also 

responsible for environmental compliance and reported to a productionoriented management structure. 

The study resulted in the following actions and lessons learned: 

• Five facilities installed air pollution control equipment that will 

permanently reduce PM10 emissions by 415 tons/year. These 

installations were in response to enforcement actions issued by the 

Region during the study. Two additional facilities eliminated 

September 1995 101 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

wood waste incineration entirely, reducing PM10 emissions by 

over 250 tons/year; 

• General industry awareness of environmental regulations has been 

improved substantially as a result of the initiated inspections, 

subsequent enforcement actions, and meetings with EPA; 

• It is important for a regulatory agency to conduct unannounced 

inspections; 

• After meeting with EPA, an industry group sponsored an opacity 

certification school in October 1991 which was attended by 

numerous industry representatives. Additional certifications have 

been held each April and October since then; 

• The problem of wood waste disposal is not only an air quality 

problem. Resolution of the enforcement cases developed in this 

study showed that recognition should be given to multimedia 

environmental impacts; 

• Most of the sources will need to obtain operating permits. 

VIII.B. EPA Voluntary Programs 

33/50 Program 

The "33/50 Program" is EPA's voluntary program to reduce toxic 

chemical releases and transfers of 17 chemicals from manufacturing 

facilities. Participating companies pledge to reduce their toxic chemical 

releases and transfers by 33 percent as of 1992 and by 50 percent as of 

1995 from the 1988 baseline year. Certificates of Appreciation have been 

given to participants who met their 1992 goals. The list of chemicals 

includes 17 high-use chemicals reported in the Toxics Release Inventory. 

Twenty-four companies and 43 facilities listed under SIC 24 (lumber and 

wood products) are currently participating in the 33/50 program. They 

account for approximately nine percent of the 491 companies under SIC 

24. This is lower than the average for all industries of 14 percent 

participation. (Contact: Mike Burns 202-260-6394 or the 33/50 Program 

202-260-6907) 

SIC Code 24 102 September 1995 
Sector Notebook Project Lumber and Wood Products 

Exhibit 29 lists those companies participating in the 33/50 program that 

reported under SIC code 24 to TRI. Many of the participating companies 

listed multiple SIC codes (in no particular order), and are therefore likely 

to conduct operations in addition to Lumber and Wood Products 

manufacturing. The table shows the number of facilities within each 

company that are participating in the 33/50 program; each company's 

total 1993 releases and transfers of 33/50 chemicals; and the percent 

reduction in these chemicals since 1988. 

Exhibit 29

Lumber and Wood Facilities Participating in the 33/50 Program

Parent Facility Name Parent City ST SIC Codes # of 

Participating 

Facilities 

1993 Releases 

and Transfers 

(lbs.) 

% Reduction 

1988 to 1993 

Blue Circle America Inc Marietta GA 2491 1 250 * 

C. M. Tucker Lumber Corp. Pageland SC 2491 2 1,000 * 

Elco Forest Products Inc Opelousas LA 2491 1 0 75 

Flagship Trading Corp Cleveland OH 2491 1 250 *** 

Georgia-Pacific Corporation Atlanta GA 2493 3 2,722,182 50 

Hagerwood Inc Grand Rapids MI 2491 2 1,000 * 

Honolulu Wood Treating Co. Ewa Beach HI 2491 1 256 50 

Hutchens Industries Inc Springfield MO 3799, 3325, 

2421 

1 298,000 68 

International Paper Company Purchase NY 2435 5 2,784,831 50 

Julian Lumber Co Inc Antlers OK 2491 1 250 50 

Louisiana-Pacific Corporation Portland OR 2421, 2435 5 294,823 50 

Mascotech Taylor MI 2426 1 3,163,830 35 

Potlatch Corporation San Francisco CA 2431, 2426 2 276,643 60 

Premark International Inc Deerfield IL 2436 3 140,313 *** 

R L C Industries Co Dillard OR 2435, 2436 1 129,083 48 

States Industries Inc Eugene OR 2435 1 16,272 50 

Tarkett North Amercn Holdings Parsippany NJ 2426 1 30,190 35 

Taylor-Ramsey Corporation Madison Heights VA 2491 1 255 *** 

Thrift Brothers Lumber Co Inc Westminster SC 2491 1 510 * 

Tri-State Pole & Piling Inc Lucedale MS 2491 1 71,255 * 

Union Camp Corporation Wayne NJ 2611, 

2621,2631 

1 835,696 50 

Weyerhaeuser Company Tacoma WA 2491 5 1,006,356 * 

Willamette Industries Inc Portland OR 2493 1 677,090 34 

Wood Preservers Inc Warsaw VA 2491 1 31 50 

* = not quantifiable against 1988 

data. 

** = use reduction goal only. 

*** = no numerical goal. 

September 1995 103 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Environmental Leadership Program 

The Environmental Leadership Program (ELP) is a national initiative 

piloted by EPA and State agencies in which facilities have volunteered to 

demonstrate innovative approaches to environmental management and 

compliance. EPA has selected 12 pilot projects at industrial facilities and 

Federal installations which will demonstrate the principles of the ELP 

program. These principles include: environmental management systems, 

multimedia compliance assurance, third-party verification of compliance, 

public measures of accountability, community involvement, and 

mentoring programs. In return for participating, pilot participants receive 

public recognition and are given a period of time to correct any violations 

discovered during these experimental projects. (Contact: Tai-ming 

Chang, ELP Director, 202-564-5081 or Robert Fentress, 202-564-7023) 

Project XL 

Project XL was initiated in March 1995 as a part of President Clinton's 

Reinventing Environmental Regulation initiative. The projects seek to 

achieve cost effective environmental benefits by allowing participants to 

replace or modify existing regulatory requirements on the condition that 

they produce greater environmental benefits. EPA and program 

participants will negotiate and sign a Final Project Agreement, detailing 

specific objectives that the regulated entity shall satisfy. In exchange, EPA 

will allow the participant a certain degree of regulatory flexibility and 

may seek changes in underlying regulations or statutes. Participants are 

encouraged to seek stakeholder support from local governments, 

businesses, and environmental groups. EPA hopes to implement fifty 

pilot projects in four categories including facilities, sectors, communities, 

and government agencies regulated by EPA. Applications will be 

accepted on a rolling basis and projects will move to implementation 

within six months of their selection. For additional information regarding 

XL Projects, including application procedures and criteria, see the May 23, 

1995 Federal Register Notice, or contact Jon Kessler at EPA's Office of 

Policy Analysis (202) 260-4034. 

Green Lights Program 

EPA's Green Lights program was initiated in 1991 and has the goal of 

preventing pollution by encouraging U.S. institutions to use energyefficient lighting technologies. The program has over 1,500 participants 

which include major corporations; small and medium sized businesses; 

Federal, State and local governments; non-profit groups; schools; 

SIC Code 24 104 September 1995 
Sector Notebook Project Lumber and Wood Products 

universities; and health care facilities. Each participant is required to 

survey their facilities and upgrade lighting wherever it is profitable. EPA 

provides technical assistance to the participants through a decision 

support software package, workshops and manuals, and a financing 

registry. EPA's Office of Air and Radiation is responsible for operating 

the Green Lights Program. (Contact: Susan Bullard at 202-233-9065 or the 

Green Light/Energy Star Hotline at 202-775-6650) 

WasteWi$e Program 

The WasteWi$e Program was started in 1994 by EPA's Office of Solid 

Waste and Emergency Response. The program is aimed at reducing 

municipal solid wastes by promoting waste minimization, recycling 

collection, and the manufacturing and purchase of recycled products. As 

of 1994, the program had about 300 companies as members, including a 

number of major corporations. Members agree to identify and implement 

actions to reduce their solid wastes and must provide EPA with their 

waste reduction goals along with yearly progress reports. EPA in turn 

provides technical assistance to member companies and allows the use of 

the WasteWi$e logo for promotional purposes. (Contact: Lynda Wynn, 

202-260-0700 or the WasteWi$e Hotline at 1-800-372-9473) 

Climate Wise Recognition Program 

The Climate Change Action Plan was initiated in response to the U.S. 

commitment to reduce greenhouse gas emissions in accordance with the 

Climate Change Convention of the 1990 Earth Summit. As part of the 

Climate Change Action Plan, the Climate Wise Recognition Program is a 

partnership initiative run jointly by EPA and the Department of Energy. 

The program is designed to reduce greenhouse gas emissions by 

encouraging reductions across all sectors of the economy, encouraging 

participation in the full range of Climate Change Action Plan initiatives, 

and fostering innovation. Participants in the program are required to 

identify and commit to actions that reduce greenhouse gas emissions. The 

program, in turn, gives organizations early recognition for their reduction 

commitments; provides technical assistance through consulting services, 

workshops, and guides; and provides access to the program's centralized 

information system. At EPA, the program is operated by the Air and 

Energy Policy Division within the Office of Policy Planning and 

Evaluation. (Contact: Pamela Herman, 202-260-4407) 

September 1995 105 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

NICE3 

The U.S. Department of Energy and EPA's Office of Pollution Prevention 

are jointly administering a grant program called The National Industrial 

Competitiveness through Energy, Environment, and Economics (NICE3). 

By providing grants of up to 50 percent of the total project cost, the 

program encourages industry to reduce industrial waste at its source and 

become more energy-efficient and cost-competitive through waste 

minimization efforts. Grants are used by industry to design, test, 

demonstrate, and assess the feasibility of new processes and/or 

equipment with the potential to reduce pollution and increase energy 

efficiency. The program is open to all industries; however, priority is 

given to proposals from participants in the pulp and paper, chemicals, 

primary metals, and petroleum and coal products sectors. (Contact: 

DOE's Golden Field Office, 303-275-4729) 

VIII.C. Trade Association/Industry Sponsored Activity 

VIII.C.1. Environmental Programs 

A consortium of Universities, DOE National Laboratories, Forest Service 

Researchers, and Industrial partners have submitted a coordinated 

package of proposals for funding under EPA's "Environmental 

Technology Initiative" (ETI) program aimed at reducing pollution in 

wood products production. A total of five proposals were submitted, 

including: "Diffusion of Pollution Prevention Technology for the Lumber 

and Wood Products Industry," "Process Control Technology to Mitigate 

VOC Air Emissions in the Production of Oriented Strand Board," 

"Improved Wood Adhesives for Reduction of Pollutants for the Wood 

Panel Manufacturing Industry," "Identification and Quantification of 

Volatile Organic Compounds Emitted from Lumber Dry Kilns," and 

"Development of Coupled Biological/Chemical Systems to Reduce VOCs 

in Lumber and Composite Board Facilities." These projects are currently 

underway at the Forest Products Laboratory in Madison, Wisconsin. 

To explore questions related to potential technologies which might be 

applicable for control of wood panel plant VOC emissions, the American 

Forest & Paper Association (AF&PA) Solid Wood Committee and NCASI 

hosted a workshop in October 1993. It was attended by approximately 

100 individuals from industry, State regulatory agencies, EPA, and EPA 

consultants. At the workshop, the following five control technologies 

were discussed: ultraviolet oxidation, chemical scrubbing with 

SIC Code 24 106 September 1995 
Sector Notebook Project Lumber and Wood Products 

brominated compounds, furnish dryer exhaust gas recirculation to a 

wood-fired fuel cell for oxidation of organic compounds, biofiltration, 

and regenerative thermal oxidation. Topics discussed included: current 

status of development, performance, problems encountered, potential 

limitations, energy requirements, and estimated costs. In addition, an 

EPA representative updated the workshop attendees on the Agency's 

current efforts to develop a common definition of VOCs and to adopt a 

standard VOC test method for emissions from solid wood manufacturing 

plants. 

According to the American Forest and Paper Association, wood recycling 

is on the rise. An estimated 400,000 tons of wood waste were recovered in 

1990. This waste included barrels, boxes, brush, Christmas trees, 

construction and demolition waste, crates, pallets, posts, poles, prunings, 

railroad ties, sawdust, slab wood, and yard trimmings. The management 

of wood residue as a component of construction and demolition waste 

and from urban tree removals is becoming a larger issue as landfill 

tipping fees rise. Wood residue management is also an increasingly 

important issue for wood products producers, retailers, and the general 

public. As virgin wood fiber prices rise, incentives and cost-avoidance 

pressures are motivating wood users and producers to find ways to fully 

and most profitably utilize this resource. 

The American Forest and Paper Association’s American Wood Council is 

producing a Wood Recycling Reference Handbook to encourage and 

facilitate wood recycling in the United States. The book will list by state 

and county where wood residue can be bought for reuse and recycling. 

The first edition is due out in October, 1995. 

VIII.C.2. Summary of Trade Associations 

There are numerous trade and professional organizations affiliated with 

the forest products industry. The largest organization is the American 

Forest and Paper Association. The smaller associations generally focus on 

specific types of timber (i.e., hardwoods, pine), or specific types of 

product (i.e., plywood, particleboard). In addition, there are a number of 

trade organizations which focus their efforts on specific regions of the 

country. 

September 1995 107 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

General 

American Forest and Paper Association 

1111 19th Street, NW, Suite 800 

Washington, DC 20036 

Phone: (202) 463-2700 

Fax: (202) 463-2785 

Members: 425 

Contact: Josephine Cooper 

The American Forest and Paper Association (AF&PA) is the national trade 

association of the forest, pulp, paper, paperboard, and wood products 

industry. AF&PA represents approximately 500 member companies and 

related trade associations (whose memberships are in the thousands) 

which grow, harvest, and process wood and wood fiber; manufacture 

pulp, paper and paperboard products from both virgin and recovered 

fiber; and produce solid wood products. 

National Council of the Paper Industry for Air 

and Stream Improvement 

260 Madison Avenue 

New York, NY 10016 

Phone: (212) 532-9000 

Fax: (212) 779-2849 

Members: 100 

Staff: 90 

Budget: $10,000,000 

Contact: Dr. Ronald Yeske, 

President 

Founded in 1943, the National Council of the Paper Industry for Air and 

Stream Improvement (NCASI) presently conducts research on 

environmental problems related to industrial forestry and the 

manufacture of pulp, paper, and wood products. NCASI produces 

technical documents on environmental issues facing the pulp and paper 

industry and conducts industry conferences. Publications include: a 

biweekly bulletin on general issues and a variety of technical bulletins 

(40/year). NCASI also holds and annual March convention in New York 

City. 

Hardwood 

Hardwood Manufactures Association 

400 Penn Center Blvd. 

Pittsburgh, PA 15235 

Phone: (412) 346-2222 

Fax: (412) 346-2233 

Members: 145 

Staff: 5 

Contact: Susan Regan 

Manufacturers of hardwood lumber and hardwood products. Conducts 

promotion programs; compiles statistics. 

SIC Code 24 108 September 1995 
Sector Notebook Project Lumber and Wood Products 

National Hardwood Lumber Association 

PO Box 34518 

Memphis, TN 38184-0518 

Phone: (901) 377-1818 

Fax: (901) 382-6419 

Members: 1300 

Staff: 40 

Contact: Ernest J. Stebbins 

United States and Canadian hardwood lumber and veneer manufacturers, 

distributors, and consumers. Inspects, measures, and certifies hardwood 

lumber. Maintains inspection training school and conducts short courses 

at members' lumber yards; conducts management and marketing 

seminars for the hardwood industry. The organization publishes the 

National Hardwood Lumber Association-Annual Report and the National 

Hardwood News, an annual newsletter. 

Plywood 

Hardwood Plywood & Veneer Association 

1825 Michael Faraday Dr. 

PO Box 2789 

Reston, VA 22090 

Phone: (703) 435-2537 

Members: 150 

Staff: 12 

Budget: $1,000,000 

Contact: E.T. Altman 

Manufactures and prefinishers of hardwood plywood; manufacturers of 

veneer; suppliers of glue, machinery, and other products related to the 

industry. Conducts laboratory testing of plywood, adhesives, finishes, 

flamespread, formaldehyde emissions, structural, and smoke density. 

The association provides public relations, advertising, marketing, and 

technical services to members. It represents the industry in legislative 

matters and keep members informed on tariff and trade actions. 

Publications include the annual Hardwood Plywood and Veneer News and 

The Executive Brief. 

American Plywood Association 

PO Box 11700 

Tacoma, WA 98411 

Phone: (206) 565-6600 

Fax: (206) 565-7265 

Members: 136 

Staff: 180 

Budget: $14,000,000 

Contact: Gene Zellner 

Manufacturers of plywood, oriented strand board and composites. 

Conducts trade promotion through advertising, publicity, merchandising, 

and field promotion. The Association provides quality oversight and 

conducts research to improve products, applications, and manufacturing 

techniques. Publications include the Management Report, and periodic 

Plywood Statistics. 

September 1995 109 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Hardboard 

American Hardboard Association 

1210 W. Northwest Highway 

Palatine, IL 60067 

Phone: (708) 934-8800 

Fax: (708) 934-8803 

Members: 4 

Staff: 

Budget: 

Contact: C. Curtis Peterson 

Manufacturers representing major U.S. producers of hardboard. 

Particleboard 

National Particleboard Association 

18928 Premiere Court 

Gaithersburg, MD 20879 

Phone: (301) 670-0604 

Fax: (301) 840-1252 

Members: 19 

Staff: 10 

Budget: 

Contact: Richard Margosian 

Mat-formed wood particleboard and medium-density fiberboard 

manufacturers interested in establishing industry product standards with 

the American National Standards Institute and quality standards for 

performance. Sponsors educational programs and publishes promotional 

and technical bulletins on topics including laminating and veneering. 

Wood Preserving 

American Wood-Preservers’ Association 

P.O. Box 286 

Woodstock, MD 21163-0286 

Phone: (410) 465-3169 

Fax: (410) 465-3195 

Members: 2000 

Staff: 

Budget: 

Contact: John F. Hall 

The association includes processors and users of chemically treated wood 

and is affiliated with the American Wood Preservers Institute. 

Publications include the annual AWPA Book of Standards, which is a 

technical handbook covering preservatives and treatments. 

SIC Code 24 110 September 1995 
Sector Notebook Project Lumber and Wood Products 

American Wood Preservers Institute 

1945 Old Gallows Road, Ste. 150 

Vienna, VA 22182-3931 

Phone: (703) 893-4005 

Fax: (703) 893-8492 

Members: 150 

Staff: 8 

Budget: $1,100,000 

Contact: Gene Bartlow 

The American Wood Preservers Institute is the national trade association 

representing the wood preserving industry. Its members include 

manufacturers of treated wood products, manufacturers and distributors 

of wood preservatives, and providers of allied services. AWPI provides 

technical forums for the industry, publishes a bi-monthly newsletter, and 

produces annual Industry Statistical Reports. 

Regional 

Northeastern Lumber Manufacturers 

Association 

272 Tuttle Rd., Box 87A 

Cumberland Center, ME 04021 

Phone: (207) 829-6901 

Fax: (207) 829-4293 

Members: 200 

Staff: 7 

Budget: 

Contact: Stephen Clark 

Northeastern Lumber Manufacturers is an association of hardwood and 

softwood lumber and timber products manufacturers in New England. 

The group promotes the interests of the Northeastern lumber 

manufacturing industry and presents the views of the industry to other 

organizations, the government, and the public. Publications include the 

monthly Northeastern Lumber Manufacturers Association. 

Southeastern Lumber Manufacturers 

Association 

PO Box 1788 

Forest Park, GA 30051 

Phone: (404) 361-1445 

Fax: (404) 361-5963 

Members: 390 

Staff: 10 

Budget: $2,000,000 

Contact: Ed C. Cone, Jr. 

Represents Southeastern hardwood and softwood lumber manufacturers 

and coordinates efforts of membership to alleviate local, regional, and 

national problems that affect the regional lumber industry. Publishes a 

quarterly newsletter, Silva Magazine, and Management Update. SLMA 

also conducts technical workshops. 

September 1995 111 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Southern Forest Products Association 

PO Box 52468 

New Orleans, LA 70152 

Phone: (504) 443-4464 

Fax: (504) 443-6612 

Members: 220 

Staff: 31 

Budget: $2,856,000 

Contact: Karl Lindberg 

The Southern Forest Products Association (SFPA) represents Southern 

pine lumber manufacturers and conducts market development and 

product promotional programs and government support activities. SFPA 

publishes a weekly newsletter covering a variety of industry activities. 

Western Wood Preservers Institute 

601 Main Street, Suite 405 

Vancouver, WA 98660 

Phone: (360) 693-9958 

Fax: (360) 693-9958 

Members: 50 

Staff: 3 

Budget: 

Contact: Dennis Hayward 

WWPI represents the treated wood industry in Western North America. 

WWPI provides educational information to assist consumers in the 

selection and proper, safe, and environmentally appropriate use of treated 

wood products. 

Western Wood Products Association 

Yeon Building 

522 SW 5th Ave. 

Portland, OR 97204-2122 

Phone: (503) 224-3930 

Fax: (503) 224-3934 

Members: 250 

Staff: 63 

Budget: 

Contact: Robert Hunt 

WWPA is a rules-writing agency (for lumber grades), approved under the 

American Lumber Standard Committee under the jurisdiction of the 

Department of Commerce. The Association also provides economic and 

statistical information on the Western lumber industry, conducts research 

in wood technology, engineering and performance; provides technical 

and educational services both domestically and internationally; and 

published technical and consumer information for Western Lumber enduse. 

SIC Code 24 112 September 1995 
Sector Notebook Project Lumber and Wood Products 

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 

General Profile 

Compilation of Air Pollutant Emissions Factors (AP-42), U.S. EPA. 

Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc., Detroit, 

Michigan, 1992. 

Price Prospects for Major Primary Commodities, 1990-2005, The World Bank, March, 1993. 

Standard Industrial Classification Manual, Office of Management and Budget, 1987. 

Sustainable Environmental Law, Campbell-Mohn, Environmental Law Institute, 1993. 

U.S. Industrial Outlook 1994, Department of Commerce. 

Wood Preserving, U.S. EPA (EPA/530-SW-90-027f). 

Wood Products Industry Associations, American Forest and Paper Association, 

Washington, D.C., January, 1994. 

1987 Census of Manufacturers Industry Series 24A: Logging, Camps Sawmills, & Planing 

Mills, U.S. Department of Commerce, Bureau of the Census, April 1990 (MC87-I-24A). 

1987 Census of Manufacturers Industry Series 24B: Millwork, Plywood, & Structural 

Materials, U.S. Department of Commerce, Bureau of the Census, April 1990 (MC87-I24A). 

1987 Census of Manufacturers Industry Series 24C: Wooden Containers & Miscellaneous Wood 

Products, U.S. Department of Commerce, Bureau of the Census, April 1990 (MC87-I24A). 

1992 Census of Manufacturers, Industry Series 24-A: Logging Camps ,Sawmills, and Planing 

Mills, U.S. Department of Commerce, Bureau of the Census, February 1995 (MC92-I24C). 

1992 Census of Manufacturers Industry Series 24B: Millwork, Plywood, and structural Wood 

Members, Not Elsewhere Classified, Bureau of the Census, February 1995 (MC92-I-24B) 

1992 Census of Manufactures Industry Series 24C: Wooden Containers and Miscellaneous 

Wood Products, February 1995 (MA2-I-24C). 

September 1995 113 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Process Descriptions 

Basic Plywood Processing, Ted Demas, American Plywood Association, Tacoma, 

Washington, December, 1992. 

Characterization of Manufacturing Processes, Emissions, and Pollution Prevention Options for 

the Composite Wood Industry, Cybele Martin and Coleen Northeim, Research Triangle 

Institute Center for Environmental Analysis, RTP, NC, March 1995. 

Encyclopedia of Science and Technology, Wood Finishing (vol. 19), Lumber Manufacture 

(vol. 10), Logging (vol. 10), 1992. 

Estimating Chemical Releases from Presswood and Laminated Wood Products Manufacturing, 

U.S. EPA, Office of Pesticides and Toxic Substances, March 1988 (EPA 560/4-88-004i). 

Forest Products and Wood Science, An Introduction, John G. Haygreen and Jim L. Bowyer, 

Iowa State University Press, 1989. 

Investigation of Emissions from Plywood Veneer Dryers, Appendix B, Plywood Research 

Foundation, March 1971. 

Modern Particleboard & Dry-Process Fiberboard Manufacturing, Thomas M. Maloney, 

Miller Freemen, Inc., San Francisco, CA, 1993. 

Study of the Physical and Chemical Properties of Atmospheric Aerosols Attributable to Plywood 

Veneer Dryer Emissions, Chemical Engineering Department, Washington State 

University, June 1981. 

Wood Products for Engineered Structures: Issues Affecting Growth and Acceptance of 

Engineered Wood Products, Donald A. Bender, Ed., Forest Products Society, Madison, 

Wisconsin, November 1992. 

Release Profiles 

Enforcement Accomplishments Report, FY 1991, U.S. EPA, Office of Enforcement 

(EPA/300-R92-008), April 1992. 

Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement 

(EPA/230-R93-001), April 1993. 

Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement 

(EPA/300-R94-003), April 1994. 

SIC Code 24 114 September 1995 
Sector Notebook Project Lumber and Wood Products 

Final Modifications to the Wood Preserving Regulations, Environmental Fact Sheet, Office of 

Solid Waste, U.S. EPA, October, 1992 (EPA/530-F-92-029). 

Surface Protection Proposed Rule, 58 Federal Register 25706, April 27, 1993. 

Unified Agenda, 57 Federal Register 21120, April 1994. 

Wood Preserving Final Rule, 57 Federal Register 61502, December 30, 1992. 

September 1995 115 SIC Code 24 
Lumber and Wood Products Sector Notebook Project 

Pollution Prevention 

Guides to Pollution Prevention: Wood Preserving Industry, U.S. EPA, Office of Research 

and Development, November 1993 (EPA/625/R-93/014). 

Pollution Prevention 1991: Progress on Reducing Industrial Pollutants, Office of Pollution 

Prevention, U.S. EPA, 1991 (EPA 21P-3003). 

Waste Minimization Practices at Two CCA Wood-Treatment Plants, U.S. EPA, Office of 

Research and Development, August 1993 (EPA/600/R-93/168). 

Contacts * 

Name Organization

Michael Caldwell American Forest and Paper

Albert Lukban American Wood Preservers Institute

Buddy Perry Perry Builders

Nicholas Latham Natural Resources Defense Council

Jim Yuhas Western Wood Products

Bill Wyndes Louisiana-Pacific

Mark Rivas U.S. EPA, Region VII (inspector)

Chris James U.S. EPA, Region X (inspector)

Maria Dixon U.S. Bureau of the Census

Kurt Bigbee American Plywood Association

John Pinkerton NCASI

Telephone 

202-463-2762 

703-893-4005 

919-492-9171 

202-624-9363 

503-224-3930 

707-443-7511 

913-551-7669 

206-553-1194 

301-763-5895 

202-565-6600 

212-532-9047 

* Many of the contacts listed above have provided valuable background information 

and comments during the development of this document. EPA appreciates this 

support and acknowledges that the individuals listed do not necessarily endorse all 

statements made within this notebook. 

SIC Code 24 116 September 1995