Materials Characterization Paper 

In Support of the 

Proposed Rulemaking: 

Identification of Nonhazardous Secondary Materials That Are Solid Waste 

Resinated Wood Products 

March 18, 2010 

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

1. Definition of Resinated Wood Products 

Resinated wood products are derived from primary and secondary wood products manufacturing 

and are generally comprised of such items as board trim, sander dust, and panel trim. These 

secondary materials may be used on-site to manufacture composites or used as fuel.

This paper focuses on resinated wood dust because of its importance as a fuel. Resinated wood 

dusts are primarily generated from the manufacturing of secondary wood products (Short 1993). 

More specifically, non-hazardous resinated wood dusts are generated from the sanding and 

sawing of engineered wood, plywood, and reconstituted wood products. 

2. Annual Quantities of Resinated Wood Dusts Generated and Used 

(1) Sectors that generate resinated wood dusts: 

The following industry sectors, listed by NAICS code, generate resinated wood dust through the 

production of wood products: 

 

• 321211 - Hardwood Veneer and Plywood Manufacturing 

 303 companies in the U.S. 

 Value of secondary wood products shipped in 2002: $168,325,000 (U.S. 

Census Bureau 2005b) 

• 321212 - Softwood Veneer and Plywood Manufacturing 

 85 companies in the U.S. 

 Value of secondary wood products shipped in 2002: $391,750,000 (U.S. 

Census Bureau 2005d) 

• 321213 – Engineered Wood Member Manufacturing 

 90 companies in the U.S. 

 Value of secondary wood products shipped in 2002: $63,617,000 (U.S. 

Census Bureau 2005a) 

• 321214 - Truss Manufacturing 

 897 companies in the U.S. 

 Value of secondary wood products shipped in 2002: $321,321,000 (U.S. 

Census Bureau 2005e) 

• 321219 – Reconstituted Wood Manufacturing 

 177 companies in the U.S. 

 Value of secondary products shipped in 2002: $146,728,000 (U.S. Census 

Bureau 2005c) 
Resinated Wood Products 

(2) Quantities and prices of resinated wood dusts generated: 

• Information on the quantity of resinated wood dust generated in the U.S. and the 

price of this material has not been identified. Such information, however, is 

available for secondary mill residues, which include resinated wood dusts and 

other secondary wood materials.1 It is estimated that approximately 12.5 million 

dry tons of secondary mill residues are generated annually in the United States. 

As indicated in Exhibit 1, the market value of both hardwood and softwood 

residues is approximately $20 per ton (Northeast Regional Biomass Program 

1999). 

Exhibit 1: Overview of Residue Generation and Prices 

Generation Price 

Type of Wood (Dry tons/yr) ($/Dry ton) 

Hardwood 4,827,200 $20.10 

Softwood 7,688,100 $20.03 

TOTAL (dry tons) 12,515,300 N/A

 (Northeast Regional Biomass Program 1999) 

(3) Trends in generation of resinated wood dusts: 

• Information on trends in generation of resinated wood dusts in the U.S. is not 

readily available. The future generation of this material, however, is likely to 

follow a similar trajectory to secondary wood production (e.g., the production of 

engineered wood, plywood, and reconstituted wood products). The future trend in 

the domestic production of secondary wood products is uncertain. Although 

growth in population and housing demand may lead to increased future 

production, a growing portion of the secondary wood sold in the U.S. is produced 

overseas (Schuler et al. 2007 and Schuler et al. 2003). 

3. Uses of Resinated wood dusts

(1) Combustion uses of resinated wood dusts: 

• Information specific to the combustion uses of resinated wood dust has not been 

identified. However, approximately 38 percent of U.S. secondary wood residues, 

which included resinated wood dust and other wood materials, are used as fuel. 

Approximately 21 percent is used as a fuel onsite, while 17 percent is sent offsite 

for fuel use at another facility (Northeast Regional Biomass Program 1999). 

 1

 Secondary mill residues are produced by secondary wood products industries that manufacture wood 

products from lumber, engineered wood products, or wood particles. Examples include wood residues from the 

manufacture of furniture, doors, cabinets, flooring, pallets, fences, and building products (Northeast Regional 

Biomass Program 1999). 

2
Resinated Wood Products 

(2) Non-combustion uses of resinated wood dusts:

• Similar to combustion uses, no information specific to the non-combustion uses of 

resinated wood dust has been identified. The largest non-combustion end use of 

secondary mill residues, however, is for animal bedding (26.2 percent) (Northeast 

Regional Biomass Program 1999). This and other end uses are summarized 

below in Exhibit 2.

Exhibit 2: End Uses of Secondary Mill Residues 

End Use Percentage (%) 

Animal bedding 26.2 

Fuel, used on site 20.7 

Fuel, sold or given away 17.3 

Landfilled or disposed as solid waste 17.2 

Mulch 4.1 

Pulp and engineered wood products 2.8 

Other 1.8 

Unknown 9.9 

Total 100

 (Northeast Regional Biomass Program 1999) 

4. Management and Combustion processes 

(1) Types of units using resinated wood dusts

• Resinated wood dusts are combusted in a variety of boilers, most of which are 

located at facilities that generate wood residues. In addition, fossil fuels can be 

used in conjunction with wood residue to account for variations in the moisture 

content of the wood (EPA 1995). 

• Among wood residue boilers that generate more than 100,000 pounds of steam 

per hour, the spreader stoker process is the most common firing method used 

(EPA 1995). 

(2) Sourcing of resinated wood dusts:

Resinated wood dusts are generated from the sawing, shaving, and trimming of 

lumber, plywood, particleboard, and other secondary wood. The combustion of wood 

residues typically occurs within those industries where it is available as a byproduct 

(EPA 1995). No information has been identified on the potential supply chain for 

sending resinated wood dust off-site for beneficial use. 

(3) Processing of resinated wood dusts: 

Some wood residues are chipped to achieve an optimal size for combustion. In 

addition, fine residues may require minor processing if fuel must be of a homogenous 

3
Resinated Wood Products 

size. Coarse residues may also require chipping to reach an ideal size (United States 

Forest Service 1977). 

(4) State regulatory status of resinated wood dusts use: 

According to state responses to a 2006 survey by the Association of State and 

Territorial Solid Waste Management Officials (ASTSWMO), two states—New York 

and North Carolina—have approved the use of recovered wood materials as a fuel 

source on at least one occasion, but it is unclear whether these approvals apply to 

vegetative (i.e., unadulterated) wood debris or the beneficial use of finished wood 

product. In both states, the beneficial use of recovered wood materials as a fuel does 

not appear to have pre-approved status (ASTSWMO 2007, p.B-42). 

5. Commodity Composition and Impacts 

(1) Composition of resinated wood dusts: 

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

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

percent wood. Exhibit 3 contains sample composition information for an engineered 

wood trim product. 

Exhibit 3: Composition of Engineered Wood Trim 

Material 

Percentage 

(%) 

Wood 90 – 91 

Resin (Phenol formaldehyde) 5 – 6 

Wax 2 – 3% 2 – 3 

Top Spray (Melamine) <1 

Laminating Adhesive <0.5 

Total 100

 (Collins Wood 2005) 

In addition, an alternative source indicates that wood dust typically contains between 

92 and 100 percent wood, and 0 to 8 percent formaldehyde (Universal Forest 

Products 2005). 

• Data from EPA suggests that the thermal value of wood dust varies from 4,500 

Btu per pound to 8,000 Btu pound. In general, a higher moisture content results 

in a lower thermal value (EPA 1995). 

(2) Impacts of resinated wood dusts use:

• Cost Impacts: The cost impacts associated with the beneficial use of resinated 

wood dusts depend on the avoided cost of disposal, the cost of the fuels displaced 

4
Resinated Wood Products 

by these materials, and the cost of beneficial use itself. Recent rates for fossil 

fuels that could be readily replaced by resinated wood dust are as follows:2

 

o Natural Gas (Industrial): $7.35 / million Btu (MMBtu) (EIA 2008a, 

Table 20) 

o No. 2 Distillate (Industrial): $16.80 / MMBtu (EIA 2008b, Table 36) 

o Residual Fuel Oil Average: $9.19 / MMBtu (EIA 2008b, Table 38) 

o Coal – Average Delivered Price in 2006: $2.23 / MMBtu (EIA 2007, 

Table ES1) 

• Emissions Impacts of Combustion: To evaluate the environmental impacts of 

burning resinated wood dust, we examined the emissions associated with burning 

wood in a boiler and compared these values to the emissions associated with the 

combustion of conventional fossil fuels, as summarized in Exhibit 4. The 

estimates in the exhibit suggest that the combustion of wood results in higher PM 

emissions than natural gas or distillate oil, but lower PM emissions than coal or 

residual oil systems. The data in Exhibit 4 also suggest that wood results in lower 

SO2 emissions than most conventional fuels. The estimated NOx emissions 

associated with wood combustion are similar to those associated with distillate 

and lower than the NOx emissions for other conventional fuels.3

 

Exhibit 4 also includes greenhouse gas emission factors associated with the 

combustion of wood. The Biomass Energy Resource Center suggests, however, 

that the net long-term effect of burning wood fuel is that no new CO2 is added to 

the atmosphere (as long as the forests from which the wood came are sustainably 

managed). This is due to the fact that when wood is burned, it recycles carbon that 

was already in the natural carbon cycle, as opposed to fossil fuels, which take 

carbon from the ground and through combustion release it to the atmosphere 

(Biomass Energy Resource Center). 

The emissions profile of treated woods may differ from the values presented in 

Exhibit 4. Because resinated wood dust may contain chemicals such as 

formaldehyde, the presence of these chemicals may cause the emissions of certain 

pollutants to be higher or lower than the values in Exhibit 4. 

• Lifecycle Emissions Impacts: Use of resinated wood dust as a replacement for 

traditional primary fuels may eliminate the environmental impacts associated with 

extraction and processing of traditional fuels. In addition to the emissions 

impacts of combustion described above, Exhibit 4 lists the quantities of the total 

cradle-to-gate emissions for these fuels based on typical processes in the United 

 2

 To express these values as dollars per Million Btu (MMBtu), the following thermal conversion factors 

were used: 1,031 Btu per 1,000 cubic foot of natural gas, 138,690 Btu per gallon of Number 2 distillate, 149,690 Btu 

per gallon of residual fuel oil, and 22,473,000 Btu per short ton of coal (EIA 2005, Tables A1, A4, and A5). 

3

 We note that the emission factors for wood presented in Exhibit 4 represent averages for wood-burning 

boilers. In addition, the wood reflected in the emissions data may include wood other than resinated wood dust. 

Emission factors for conventional fuels are based on typical boilers in use in North America in the late 1990s. 

5
Resinated Wood Products 

6

States in the late 1990s, with wood scrap combustion presented as an indicator of 

the emissions likely from the combustion of resinated wood dust. Note that there 

may be alternative uses (e.g., animal bedding) that are environmentally preferable 

to combustion. 
Exhibit 4: Comparative Impacts of Wood Combustion versus Alternative Primary Fuels 

Wood Coal Distillate Fuel Oil Residual Fuel Oil 

Combustion Combustion 

Combustion 

plus 

Upstream Combustion 

Combustion 

plus 

Upstream Combustion 

Combustion 

plus 

Upstream Co

Pollutant 

------------------------------------------- lb./MMBtu ------------------------------------

Criteria Pollutants PM2.5 - - - - - - - PM10 0.019 0.054 0.054 0.011 0.011 0.093 0.093 PM, unspecified - - 0.246 - 0.012 - 0.012 NOx 0.167 0.482 0.504 0.173 0.234 0.367 0.428 VOCs - 0.006 0.014 0.001 0.363 0.002 0.367 SOx 0.008 1.446 1.469 0.209 0.394 1.593 1.781 CO 1.511 0.068 0.085 0.036 0.082 0.033 0.079 Pb 1.33x10-4 8.93x10-6 9.19x10-6 4.60x10-6 5.61x10-6 5.80x10-5 5.90x10-5 Hg - 2.05x10-6 2.14x10-6 1.58x10-6 1.77x10-6 8.67x10-6 8.85x10-6 Greenhouse Gases CO2 233.3 210.7 214.7 161.2 180.1 173.3 192.5 CH4 - 0.007 0.458 3.74x10-4 0.03 0.007 0.036 N2O - 0.003 0.003 - 2.01x10-5 - 2.07x10-5 MTCO2E/MMBtu 0.106 0.096 0.102 0.073 0.082 0.079 0.088 Source:Franklin Associates 1998. Note:

“-” signifies data not available; may equal zero. The emission information presented in this table is derived from Life Cycle Inventory (LCI) data, as compiled by Franklin Associates. quantifies resource inputs, energy requirements, and releases to the air, water, and land for each step in the manufacture of a product or extraction of the raw materials to ultimate disposal. The LCI can be used to identify those system components or life cycle steps that arto environmental burdens such as energy use, solid waste, and atmospheric and waterborne emissions. Uncertainty in an LCI is due to input uncertainties and data variability. There are several life cycle inventory databases available in the U.S. and Europe. For this paper, we applied the most readily available 

most consistent with the materials and uses examined. These LCI data rely on system boundaries as defined by Franklin Associates, as 

documentation for this database, available at: http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf. 
References 

ASTSWMO. 2007, ASTSWMO 2006 Beneficial Use Survey Report (Association of State and Territorial Solid 

Waste Management Officials, Washington, DC). 

 

Biomass Energy Resource Center. "Emissions and Air Quality," Available at: 

http://www.biomasscenter.org/information/emissions.html 

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

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

Franklin Associates. 1998, “Franklin US LCI 98 Library”. 

 

Short, Paul. “Mississippi’s Wood Products Manufacturing Industries,” 1993. Accessed on April 14, 2009 at: 

http://www.p2pays.org/ref/01/00453.pdf 

Northeast Regional Biomass Program. “Secondary Mill Residues and Urban Waste Quantities in the United States,” 

1999. Accessed on April 18, 2009 at http://www.nrbp.org/pdfs/pub21.pdf. 

Schuler, Albert and Craig Adair. “Engineered and Other Wood Products - An Opportunity to ‘Grow the Pie’,” paper 

presented at the 37th International Wood Composite Materials Symposium, Washington State University, April 

2003. Accessed on April 21, 2009 at http://www.ahc.caf.wvu.edu/usdafs/WEB_Documents/577.pdf. 

Schuler, Albert and Steve Lawser. “The U.S. Furniture Industry: Yesterday and Today ... Will There Be a 

Tomorrow?,” Wood Digest, June 2007, pp. 20-22. Accessed on April 21, 2009 at 

http://www.ahc.caf.wvu.edu/usdafs/web_documents/664.pdf 

United States Census Bureau. “Engineered Wood Member (Except Truss) Manufacturing: 2002,” 2005a. Accessed 

on April 18, 2009 at: http://www.census.gov/prod/ec02/ec0231i321213.pdf 

United States Census Bureau. “Hardwood Veneer and Plywood Manufacturing: 2002,” 2005b. Accessed on April 

18, 2009 at: http://www.census.gov/prod/ec02/ec0231i321211.pdf 

United States Census Bureau. “Reconstituted Wood Product Manufacturing: 2002,” 2005c. Accessed on April 18, 

2009 at: http://www.census.gov/prod/ec02/ec0231i321219.pdf 

United States Census Bureau. “Softwood Veneer and Plywood Manufacturing: 2002,” 2005d. Accessed on April 

18, 2009 at: http://www.census.gov/prod/ec02/ec0231i321212.pdf 

United States Census Bureau. “Truss Manufacturing: 2002,” 2005e. Accessed on April 18, 2009 at: 

http://www.census.gov/prod/ec02/ec0231i321214.pdf 

United States Energy Information Administration (EIA). 2005, Annual Energy Review 2004. 

United States Energy Information Administration (EIA). 2007, Annual Coal Report 2006. 

United States Energy Information Administration (EIA). 2008a, “Natural Gas Monthly: July 2008”. 

United States Energy Information Administration (EIA). 2008b, “Preliminary Petroleum Marketing Annual 2007”. 

United States Environmental Protection Agency. “AP 42, Fifth Edition: Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources,” 1995. Accessed on April 14, 2009 at: 

http://www.epa.gov/ttnchie1/ap42/ch01/final/c01s06.pdf 

8 
Resinated Wood Products 

United States Forest Service. “Secondary Wood Residue: Production, Use, and Potential in the Twin City Area, 

1977. Accessed on April 15, 2009 at: http://www.ncrs.fs.fed.us/pubs/rp/rp_nc144.pdf 

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

http://www.ufpi.com/literature/wooddust-165.pdf 

9