### Materials Characterization Paper In Support of the Proposed Rulemaking:

Identification of Nonhazardous Seco ndary Materials That Are Solid Waste

Resinated Wood Products

March 18, 2010



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1. Definition of Resinated Wood Products

Resinated wood products are derived from prim ary 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 manuf acturing of secondary w ood 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 id entified. 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 ge nerated 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 w ood products is uncertain. Although growth in population and housing dema nd may lead to increased future production, a growing portion of the secondary wood sold in the U.S. is produced overseas (Schuler et al. 2 007 and Schuler et al. 2003).

3. Uses of Resinated wood dusts

(1) Combustion uses of resinated wood dusts:

• Information specific to the combustion us es of resinated wood dust has not been identified. However, approximately 38 pe rcent of U.S. secondary wood residues,

which included resinated wood dust and othe r 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 (Nor theast 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).

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### (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 an imal 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 s econdary wood. The combustion of wood residues typically occurs within those indus tries where it is av ailable as a byproduct (EPA 1995). No information has been iden tified 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 achie ve an optimal size for combustion. In addition, fine residues may requ ire minor processing if fuel must be of a homogenous

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### size. Coarse residues may also require chippi ng to reach an ideal size (United States Forest Service 1977).

(4) State regulatory status of res inated wood dusts use: According to state respons es to a 2006 survey by the Association of State and Territorial Solid Waste Management Offi cials (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 unc lear 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 wo od materials as a fuel does not appear to have pre-approve d 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 co mposition 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 s ource 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 therma l 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

4Resinated Wood Products



### by these materials, and the cost of benefi cial use itself. Recent rates for fossil

fuels that could be read ily replaced by resinate d wood dust are as follows: 2



### o Natural Gas (Industrial): $7.35 / m illion 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 th e combustion of wood results in higher PM emissions than natural gas or distillate oi l, but lower PM emissions than coal or residual oil systems. The data in Exhibit 4 also suggest that wood results in lower

SO 2 

### emissions than most conventional fuels. The estimated NO

x 

### emissions

associated with wood combustion are simila r to those associated with distillate

and lower than the NO

x 

### emissions for other conventional fuels. 3



### Exhibit 4 also includes greenhouse gas em ission factors associated with the

combustion of wood. The Biomass Ener gy Resource Center suggests, however, that the net long-term effect of burning wood fuel is that no new CO 2 

### is added to the atmosphere (as long as the forests from which the wood came are sustainably managed). This is due to th e 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 ma y differ from the values presented in

Exhibit 4. Because resinated wood dus t may contain chemicals such as formaldehyde, the presence of these chemi cals 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 fu els. In addition to the emissions impacts of combustion described above, E xhibit 4 lists the quantities of the total cradle-to-gate emissions for these fuels based on typical pro cesses 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.

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### 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 beddi ng) that are environmentally preferable

to combustion.Exhibit 4: Comparative Impacts of WoodCombustion versus Alternative Primary FuelsWoodCoalDistillate Fuel OilResidual Fuel OilNatural GasCombustionCombustionCombustionplusUpstreamCombustionCombustionplusUpstreamCombustionCombustionplusUpstreamCombustionCombustionplusUpstreamPollutant------------------------------------------- lb./MMBtu ---------------------------------------Criteria PollutantsPM2.5---------PM100.0190.0540.0540.0110.0110.0930.0930.0090.009PM,unspecified--0.246-0.012-0.012-0.004NOx0.1670.4820.5040.1730.2340.3670.4280.3010.417VOCs-0.0060.0140.0010.3630.0020.3670.0090.524SOx0.0081.4461.4690.2090.3941.5931.7810.0731.985CO1.5110.0680.0850.0360.0820.0330.0790.0580.282Pb1.33x10-48.93x10-69.19x10-64.60x10-65.61x10-65.80x10-55.90x10-5-2.72x10-7Hg-2.05x10-62.14x10-61.58x10-61.77x10-68.67x10-68.85x10-6-7.18x10-8Greenhouse GasesCO2233.3210.7214.7161.2180.1173.3192.5114.6129.8CH4-0.0070.4583.74x10-40.030.0070.0360.0030.372N2O-0.0030.003-2.01x10-5-2.07x10-5-1.17x10-5MTCO2E/MMBtu0.1060.0960.1020.0730.0820.0790.0880.0520.062Source: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. LCI data identifies andquantifies resource inputs, energyrequirements, and releases to the air, water,and land for each step in the manufacture of aproduct or process, from theextraction of the raw materials to ultimate disposal. The LCI canbe used to identify those systemcomponents or life cycle steps that are the main contributorsto environmental burdens such as energy use, solid waste, and atmospheric and waterborne emissions. Uncertainty in an LCI is due to the cumulative effects ofinput 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 readilyavailable LCI database that wasmost consistent with the materials and uses examined. These LCI data rely on system boundaries as defined by Franklin Associates, as described in thedocumentation 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/WoodProduct s/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 Resi dues 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 Ma terials 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. Furn iture Industry: Yesterday and Today ... Will There Be a
Tomorrow?,” Wood Digest , June 2007, pp. 20-22. A ccessed on April 21, 2009 at http://www.ahc.caf.wvu.edu/usdafs/web_documents/664.pdf

United States Census Bureau. “Engin eered Wood Member (Ex cept 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 Pl ywood 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 Plyw ood 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 Informati on Administration (EIA). 2005, Annual Energy Review 2004

.

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

.

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

United States Energy Inform ation 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

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United States Forest Service. “Second ary Wood Residue: Production, Use, an d Potential in the Twin City Area, 1977. Accessed on April 15, 2009 at: http ://www.ncrs.fs.fed.us/pub s/rp/rp_nc144.pdf

Universal Forest Products, Inc. “Material Safety Data Sheet: Wood Dust,” 2005. Acces sed on April 15, 2009 at: http://www.ufpi.com/literature/wooddust-165.pdf

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