### Materials Characterization Paper In Support of the Final Rulemaking: Identification of Nonhazardous Secondary Materials That Are Solid Waste

Biomass - Forest Derived Bioma ss and Pulp and Paper Residues

February 3, 2011



### ================== ================== ================== ==============

1. Definitions of Forest Derived Biom ass and Pulp and Paper Residues

The forest products industry generates large am ounts of residual biomass as timber is harvested and manufactured into marketable goods such as lumber and paper. Forest derived biomass may originate directly from the forest (logging residue s) or from timber processing mills (primary mill residues). Logging residues include tree tops and small branches that are typically left uncollected during logging operations. Primary mill residues consist of bark residues, coarse residues such as chunks and slabs, and fine resi dues such as shavings and sawdust generated at sawmills that process harvested timber. Other forest derived biomass produced by this industry include residues from woodworking shops, fu rniture factories, and truss and pallet manufacturing (secondary mill residues). These mate rials have typically been used for their fuel value in paper operations, as well as disposed of in landfills. 1 

### For the purposes of this paper,

forest derived biomass does not include resinated wood produc ts. A separate materials characterization paper has been de veloped for this material.

Another source of biomass fuels from the forest products industry is pu lp and paper residuals, black liquor, 2 

### and wastewater treatment sludges. Black li quor (which is not included in pulp and paper sludge category as described in the final rule and should be cons idered separately) is generated in the kraft process, which in 2000 accounted for 83 percent of domestic pulp production. Black liquor consists of lignin and pulp ing chemicals used to separate lignin from

the cellulosic fraction of w ood. Sludges, both primary and secondary, are produced from wastewater treatment of process effluents. Pr imary sludges originate fr om primary wastewater treatment operations (i.e., sedimentation or prim ary clarification operations) and consist of wood fiber and inorganic materials, while seconda ry sludges come from secondary / biological

1 Other materials are sometimes identified as Forest Produ ct Industry (FPI)-derived fuels in the literature; these include wood products found in ba les of cardboard (old cardboard container, or OCC, rejects), turpentine and derivatives, biogases recovered from industrial waste water treatment systems or landfills, methanol from strippers, and “tall oil” from pine processing. These are not discussed in detail here for a variety of reasons. In some cases (e.g., biogases and turpentine) they are included in other ma terials characterization papers. In other cases, it is not clear whether the materials are already co nsidered part of another material (e.g ., OCC rejects) or are used as fuel with any frequency (e.g., tall oil). Public comments submitte d by Michigan Biomass in response to the Advanced Notice of Proposed Rulemaking indicate that pallets, crat e material, and cardboard are additional wood and paper materials commonly used as fuel (Van Til 2009).

2 Black liquor may be burned under certain conditions an d is not defined as a solid waste for purposes of the hazardous waste regulations. The rule (Definition of Solid Waste Final Rule, January 4, 1985 at 50 FR 641-642) covering this non waste determination for black liquor is not being reopened in this rule. With respect to comparable fuels, black liquor is consid ered a legitimate non-wast e fuel because it meets th e chemical and physical specifications of a traditional benchmark fuel.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### treatment operations and are composed largely of microbial biomass. Note that use of sludges associated with municipal wastewater treatment (i.e., sewage treatment) plants as fuel is addressed in a separate paper.

2. Annual Quantities of Forest Derived Bioma ss and Pulp and Paper Residues Generated

and Used

(1) Sectors that Generate Forest Derived Bi omass and Pulp and Paper Residues:

• NAICS 113310: Logging

• NAICS 3221: Pulp, Paper, and Paperboard Mills

• NAICS 32111: Sawmills and Wood Preservation

• NAICS 32121: Veneer, Plywood, and Engi neered Wood Product Manufacturing

(2) Quantities and Prices of Forest Derive d Biomass and Pulp and Paper Residues

Generated:

• Perlack et al . (2005) estimated production of logging and other removal residues

at 67.1 million tons 3 

### , 41.9 million tons of which is av ailable for recovery. This is consistent with Milbrandt (2005), who estimated total production at 62.4 million tons. McKeever (2004) estim ated total production at 103 million tons with 92.6 million tons available for recovery. Unlike the other two studies, McKeever included 17.6 million tons of stumps and limbs. Each of these three studies was

derived from the USDA Forest Servi ce’s Timber Product Output Database.

• Total primary mill residue production ranges from 86.8 to 91.4 million tons (McKeever 2004, Perlack et al. 2005, Milbrandt 2005).

• Pulp and paper mills produce the dry biomass equivalent of 52.1 million tons of black liquor (Perlack et al. 2005) and between 4.2 and 5.8 million tons of

wastewater treatment slu dges (ITC 2002, Thacker 2007).

• Gan (2007) estimates for forest residue a median total market price (including transport) of $40 per dry ton with a ra nge from $36 to $45. Current prices for primary mill residues are undetermined, although there is evidence to suggest that prices have increased substantially in recent years ( e.g. , sawdust priced at $25 a ton in 2006 to over $100 per ton in so me markets in 2008) (Millman 2008).

• No established commercial market for black liquor exists as it is utilized within pulp and paper mills. Prices for sludges are undetermined.

(3) Trends in Generation of Forest Derive d Biomass and Pulp and Paper Residues:

• Domestic primary mill residue producti on decreased from 113.4 million tons in 1990 to 83.4 million tons in 2002 (McKeever 1999, Smith et al. 2004).

• Domestic pulp and paperboard capacity de creased at an averag e annual rate of 0.7 percent for the period from 2000 to 2007 (AF&PA 2008).

• US timber harvest is expected to in crease 24 percent by 2050 according to the Fifth Resources Planning Act Timber Assessment (Haynes and Skog 2002). This increase will be exclusively in th e harvest of nonsa wtimber trees.

• Perlack et al. (2005) predict that by 2050 increase s in availability of logging and other removal residues by 23 million tons , pulping liquors by 22 million tons, and

3 Biomass production estimates are presented on an annual basis.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### primary and secondary mill residues by 16 million tons. An additional 60 million tons of forest biomass may also be avai lable should widespread fuel treatments for reducing fire hazards be implemented.

3. Uses of Forest Derived Bioma ss and Pulp and Paper Residues

(1) Combustion Uses of Forest Derived Biomass and Pulp and Paper Residues:

• Public comments submitted by Michigan Biomass in response to the Advanced Notice of Proposed Rulemaking (ANPRM) st ate that logging residues, including some whole tree chips, are a primary source of fuel for wood-fired power plants (Van Til 2009).

• The International Paper Products Cor poration’s public comments on the ANPRM indicate that biomass power plants in New England currently pay approximately $30 per ton for whole tree chip woody biomass ($3.50 per million Btu). In addition, these comments state that the cost of paper derived fuel to all fossil fuel fired power plants is approximately $55 per ton ($2.75 per million Btu) (Dupuis 2009).

• Public comments submitted by Graphic P ackaging Internati onal, Inc. on the ANPRM the present costs for loading, hauling, and disposal of the sludge are approximately $25 per ton of mill residuals (Hanson 2010).

• Primary mill residues tend to be clean, uniform, concentrated, and with a lowmoisture content (Perlack et al . 2005). They are, therefore, highly desirable as a fuel as well as for other purposes. Currently, only between 1.7 and 1.9 million tons are unused (McKeever 2004, Perlack et al. 2005, Milbrandt 2005).

• Approximately 42 percent of all primary mill residues are used as fuel, including 76 percent of bark residues, 12 percent of coarse residues, and 56 percent of fine residues (Smith et al . 2004).

• Essentially all black liquors produced in pulp and paper opera tions are combusted as fuel in pulping liquor recovery furn aces. These furnaces provide process energy and recover pulping agents (e.g., s odium sulfide) used to form fresh cooking liquor (Perlack et al. 2005, Carrott and Carrott 2007).

• In 2002, 21.9 percent of pulp and paper mill sludges were combusted as fuel (Thacker 2007). An undetermined fraction of sludges was used as a cement kiln feedstock and as a fuel pellet ingredient.

• The combustor survey database devel oped by EPA for the 2009 proposal of the

Commercial and Industrial Solid Waste Incinerator (CISWI) standards and the

Industrial Boilers Maximum Achievable Control Technology (MACT) standards indicates that the sources surveyed for these rules annually combust approximately 46.5 million tons of materi al characterized as forest-derived biomass, 475,000 tons of pulp and paper residues (excluding black liquor), and 3.4 million tons of black liquor. 4,5 

### Surveyed combustion units also reported

4 The materials in the combustor survey database that we assume are forest-derived biomass include hog fuel, knots and knotter rejects, adulterated wood, bark, engineered wood pellets, painted or varnished wood, plywood and particleboard, treated wood, cardboard, unadulterated wood, unadulterated lumber, and unadulterated timber. Materials that we assume are pulp and paper resi dues (excluding black liquor) include hydro pulper refuse, kraft pulp fiber, OCC plant rejects, OCC rejects, paper an d paper residues, paper pellets, pulp mill tailings, recycle fiber lightweight rejects, tall oil and its derivatives, and wood oil. Note that some of the materials characterized asBiomass - Forest Derived Biomass and Pulp and Paper Residues

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### burning approximately 3.2 million tons of bi omass material per year that may or may not be forest-derived or pulp and paper residues 6 

### (EPA 2009).

• It has been estimated that thermal oxi dation of paper sludge can supplement as much as 11 to 34 percent of fossil fuel demand for a medium-size mill (CANMET Energy Technology Centre 2005).

(2) Non-Combustion Uses of Forest Derive d Biomass and Pulp and Paper Residues:

• Logging residues left on harvested timbe rland help control erosion, replenish nutrients, and maintain so il productivity. It is unknow n what fraction can be removed without disrupting these benefits, a nd this is likely to vary by location.

• Around 56 percent of primary mill residues are used for non-combustion purposes. This includes 20 percent of bark residues, used largely for shredded mulches, and 78 percent and 23 percent of coarse and fine residues, respectively, used for woodpulp, nonstructural panels , and animal bedding (McKeever 2004,

Smith et al. 2004). The specific uses are driv en by economic considerations.

• In 2002, 14.6 percent of pulp and paper mill wastewater treatment sludges were applied to land as a soil conditioner, fertilizer, limi ng agent, or mulch (Sippola et
al. 2003, Thacker 2007). Around 11.7 percent had other beneficial uses, including as papermaking fiber, industrial absorb ent, animal bedding, manufactured soil component, compost feedstock, landfill barrier cover (Zule et al. 2007), acid mine drainage control cover, bu ilding board/fixture (Scott et al. 2000), glass or lightweight aggregate, and brick or concrete additive (Naik 2004, Thacker 2007). Sludges are also being considered as a feedstock for ethanol production (Fan and Lynd 2007).

• Public comments submitted by the Paper Recycling Coalition following the

release of the ANPRM indicate that the paper industry relies on recovered paper for 37 percent of its raw material. The pape r industry utilizes recovered fibers to manufacture industrial/retail packaging, newsprint, commercial food-service supplies, and other products (Colling and McPoland 2009).

(3) Quantities of Forest Derived Biomass a nd Pulp and Paper Residues landfilled:

• Of the residues described in this sec tion, only pulp and paper mill wastewater treatment sludges are landfilled to any appreciable extent.

• In 2002, approximately 51.8 percent of sludges were disposed of in landfills or lagoons, typically onsite (Thacker 2007, IT C 2002). There is a trend toward reduced disposal of sludges in landfills largely due to higher landfilling prices and higher fossil fuel prices (Mahmood and Elliott 2006, de Alda 2008).

wood in the combustor database may be construction and demolition debris (as defined in the three construction and demolition debris materials characterization pape rs) rather than fore st-derived biomass.

5 Although we report forest-derived biomass and pul p and paper residues from the combustion database as tonnages, the database includes material quantities expressed in terms of heating values (Btu). To express this information as tonnages, we converted from Btu values to tons by assuming thermal values ranging from 4,740 to 7,975 Btu per pound for forest-derived biomass, 1,810 to 17,000 Btu per pound for various pulp and paper residues (excluding black liquor), and 5,880 Btu per pound for black liquor.

6 The biomass categories in the combustor database that may or may not be forest-derived biomass or pulp and paper residue include materials char acterized as bio-liquids or biomass.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### (4) Quantities of Forest Derived Biomass and Pulp and Paper Residues Stockpiled/Stored:

• The amount of logging residues that is uncollected is unknown, and these tend to undergo rapid decomposition after timber harvest.

• Black liquors are cycled through pulp a nd paper mills on a continuous basis.

• Stockpiled/stored quantities of primary mill residues and pulp and paper mill wastewater treatment sludges are undetermined.

Exhibit 1: Overview of Generation and Use of Forest Derived Biomass and Pulp and Paper

Residues

Commodity Annual Quantity

Generated Annual Quantity Used

as Fuel Annual Quantity

Landfilled Annual Quantity in

Other Uses Total Quantity Stockpiled as

of 2007 Cement

Kilns Other

------------ --- Million Tons

--------- ------ Logging

Residues 41.9 – 92.6 0 0 0 0 0 Primary Mill

Residues 86.8 – 91.4 N/I 35.3 0 46.4 N/I

Black Liquor 52.1 0 52.1 0 0 0

Sludges 4.2 – 5.8 N/I 0.9 – 1.3 2.2 – 3.0 1.1 – 1.5 N/I

N/I = not identified



### 4. Management and Combustion Processes fo r Forest Derived Biomass and Pulp and Paper Residues

(1) Types of Units Using Forest Derived Biom ass and Pulp and Paper Residues as a

Fuel:

• Forest derived biomass are used as a fuel in a variety of boilers including Dutch ovens, fuel cell ovens, spreader stokers, suspension-fired boilers, and fluidized bed combustion boilers (EPA 2003). Scrap w ood may be co-fired with other fuels, primarily coal (Mann and Spath 2001).

• In the kraft pulping process, black liquor is combusted as a fuel in a pulping liquor recovery furnace. Sludges may be co mbusted as a fuel in hog fuel boilers, as a supplementary fuel, or in fluidized bed boilers (Sell 1992).

(2) Sourcing of Forest Derived Biomass and Pulp and Paper Residues:

• Logging and primary milling residues are generated during timber harvest and milling operations.

• Black liquor is spent cooking liquor from the kraft pulping process (EPA 1995). Sludges originate from wastewater treatment and, in the case of mills utilizing discarded paper sources, de-inking processes.

(3) Processing of Forest Derived Biom ass and Pulp and Paper Residues:

• Logging and primary milling residues ma y be chipped or sorted before combustion so that they can be efficiently burned as fuel. They may also be dried (cured).Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### • Black liquor undergoes a series of concentr ating steps before being combusted as a fuel. Weak black liquor is first concentrated to about 55 percent solids by a multiple-effect evaporator system, and th en to around 65 percent by a directcontact evaporator or indirect-con tact concentrator (EPA 1995, EPA 2002).

• Pulp and paper mill sludges typically undergo mechanical dewatering before being combusted as fuel, with minimu m solids content of around 40 percent needed for sustained combustion (Se ll 1992, Caputo and Pelagagge 2001). Some sludges are dried to 70 to 95 percent solids (Thacker 2007).

(4) State Status of Forest Derived Bioma ss and Pulp and Paper Residues Use as

Fuel: According to state respons es to a 2006 survey by the Association of State and Territorial Solid Waste Management Officials (ASTSWMO 2007), Iowa and Mississippi have approved the use of pulp and paper residue as fuel rather than as a waste. This use in these states has a pr e-approved status, sugge sting that a case-bycase approval process for designation of beneficial use is not necessary for this use (ASTSWMO 2007, p.B-25). In addition, Mich igan reports that in at least one instance the use of pul p and paper residues as fuel has been approved as a beneficial

use.

As of September 2006, approximately 50 pe rcent of states had renewable fuels portfolio standards requiring that varying pe rcentages of power generated within the

individual states come from alternativ e fuels (including biomass) by a designated future date; several more states have en acted such regulations since then (DOE 2006). 7



### 5. Forest Derived Biomass and Pulp and P aper Residues Composition and Impacts

(1) Thermal Value of Forest Derived Bi omass and Pulp and Paper Residues:

• The heating values of forest derived bi omass and pulp and pape r residues depend upon moisture content.

• The heating value for dry (0 percent moisture) woody materials 8 

### is typically between 15.5 and 16.4 million btu/ton (7,750 to 8,200 btu/lb) (Wright et al. 2006). Wood fired in the lumber and pulp and paper industries has an average moisture content of 50 percent, with a heating value of between 9 and 10 million btu/ton (4,500 to 4,980 btu/lb) (EPA 2003, EIA 2008).

• The average heating value of dry black liquor is 11.8 million btu/ton (5,880 btu/lb) (EPA 1995), with a range of 11.6 to 13.4 million btu/ton (5,820 to 6,680 btu/lb) (Niemelä and Alén 1999). The heat ing value of hydrated black liquor as enters the recovery boiler tends to be 20 to 25 percent less ( i.e. , average 9.1 million btu/ton (4,560 btu/lb) with a range of 9.0 to 10.4 million btu/ton (4,510 to 5,180 btu/lb)) (Niemelä and Alén 1999).

• A mixture of primary and secondary sludge s as generated by the pulp and paper industry may have a heating value of 3.6 million btu/ton (1,810 btu/lb) at 63

7 The summary table in the referen ce does not always specify which types of biomass are included, however, it is likely that woody biomass is incl uded. For example, Ne vada specifies “wood”.

8 Also called the gross or higher heating value.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### percent moisture (Tarnawski 2004). Sell (1999) and EIA (2008) describe an average sludge heating value of unknown moisture content of 12.0 and 7.5 million btu/ton (6,000 and 3,760 bt u/lb), respectively.

(2) Chemical Composition of Forest Derived Biomass and Pulp and Paper Residues:

• Exhibit 2 presents the chemical compos ition of four types of forest-derived biomass for which constituent information was readily available: bark, virgin wood, woodchips, and general (unspecified ) biomass. Based on the available data, constituent values for forest derive d biomass generally fall within the range of traditional fuels, with a few exceptions. The lead content in biomass is 1.44 ppm, which is lower than any of the othe r traditional fuels, even bituminous coal, with a range of 2-80 ppm.

Exhibit 2: Constituents of Forest Derived Biomass

Constituent Forest Derived Biomass

Biomass 1

(not specified) Virgin

Wood 2 Bark (Spruce) 3 Woodchips (Spruce) 3

-----Values in parts per million (ppm)-----
Cadmium (Cd) 0.24 0.13 0.2-0.9 0.06-0.4
Arsenic (As) 1.27 0.00 0.2-5 0-1.5
Chromium (Cr) 5.22 0.13 1.6-14 1.6-17
Nickel (Ni) 2.56 0.18 1.6-13 1.7-11
Selenium (Se) 0.95 0.00 - -
Manganese (Mn) 211.5 - 430-1,300 63-900
Cobalt (Co) 1.25 - - -
Lead (Pb) 1.44 0.33 0.9-4.4 0.3-2.7
Antimony (Sb) 0.6 0.03 - -
Beryllium (Be) 0.15 - - -
Mercury (Hg) 0.012 0.20 0.01-0.17 0.01-0.17

Fluorine (F) 20.85 - - -
Phosphorus (P) 369.13 - 380-670 97-340
Sulfur (S) 97.27 2,000 - -

Nitrogen (N) 9,000 - -

Notes:

Blank cells indicate no data available

1 OAQPS (2010)

2. Jambeck, et al. (2007).

3 . Van Loo, Sjaak and Koppejan, Jaap. "The Handbook of Biomass Combustion & Co-firing." Earthscan Publishing, 2008. Pp 44-55.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### • Given the variety of sludges generated by pulp and paper facilities during the manufacturing process (e.g., de-inking residuals, mechanical pulp mill sludge, etc.), the chemical composition of pulp and paper sludge is highly variable.

Exhibit 3 summarizes the constituent concen trations for severa l types of pulp and paper sludge for which data were available. As an illustration of the differences

in constituent concentrations across diffe rent types of sludges, the concentration of sulfur is considerably higher in black liquor solids th an the rest of the sludge sub-types.

(3) Emissions Impacts of Using Forest Derive d Biomass and Black Liquor as a Fuel:

• To evaluate the environmental impacts of burning forest derived biomass, we

examined the emissions associated with burning wood in a boiler and compared

these values to the emissions associat ed with the combustion of conventional fossil fuels, as summarized in Exhibit 2. 9 

### The estimat es in the exhibit suggest

that the combustion of wood results in higher PM emi ssions than natural gas or distillate oil, but lower PM emissi ons than coal or residual oil systems. Therefore, they fall within the range of t ypical fuels. The data in Exhibit 2 also suggest that wood results in lower SO 2 

### emissions than most conventional fuels.

The estimated NOx emissions associated with wood combustion are similar to

those associated with distillate and lower than the NO

x 

### emissions for other

conventional fuels. 10



### • Public comments from the International Paper Products Corpor ation indicate that emissions from the proper combustion of paper derived fuel (PDF) are cleaner

than emissions associated with the combus tion of coal and Number 6 fuel oil due to the relatively low nitrogen and sulfur content of PDF (Dupuis 2009).

• Combustion of black liquor as a fuel in a recovery boiler with an electrostatic precipitator yields 0.2 lbs. particulate matter per MMBtu. Combustion without pollution controls emits vastly higher particulate matter, ranging upwards of 15 lbs./MMBtu. Regardless of pollution controls employed, SO 2 

### emissions equal 0.6 lbs./MMBtu, while CO emissions are 0.9 lbs./MMBtu (EPA 1995, p.10.2-5).

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

9 Public comments submitted by Michigan Biomass in response to the ANPRM suggest that the information in Exhibit 4 overstates the lead emissions associated with burning wood. The exhibit lists a lead emission rate that is 2 orders of magnitude higher for wood than for coal and 1 order of magnitude higher than residual oil. Michigan Biomass asserts that it has never found lead emissions to be this high, even in cases where construction and demolition wood is fired (Van Til 2009).

10 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 forest derived biomass.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### carbon from the ground and through combustion release it to the atmosphere (Biomass Energy Resource Center).Biomass - Forest Derived Biomass and Pulp and Paper Residues10Exhibit 3: Constituents of Pulp and Paper SludgeConstituentPulp and Paper SludgeDe-inkingpapersludge1Hydropulperrefuse2Mechanicalpulp millsludge3Kraftmillsludge4Recyclepaper millsludge5Pulp mill, other nonspecified pulp and papersludges6-----Values in parts per million (ppm)-----Cadmium (Cd) <1 0.3 0.3-1.38 0Arsenic (As) <10 1.64Chromium (Cr) 3.8-5.6 2.37 2.5-14.7 0.4Mercury (Hg) 0-0.6Nickel (Ni) <10 10.52 4.3-16.0 0.4Boron (B) <5 0.5Potassium (K) 94-214 650-5,290 151Selenium (Se) <2Molybdenum (Mo) <2Manganese (Mn) 13-27 173.88 27Magnesium (Mg) 406-840 364Iron (Fe) 261-595 143Copper (Cu) 92-130 1.6-37.0 5Cobalt (Co) <2 0.5Lead (Pb) <20 2.03 <1.5-7.06 5Zinc (Zn) 17-61 22.0-114 31Antimony (Sb) 0.79Beryllium (Be) 0.032Fluorine (F) 24.13Phosphorus (P) 331.38 1,528-7,950 57Sulfur (S) 5-20 8,000-10,00020-30Calcium (Ca) 6014-106124,080-12,800 76,292Nitrogen (N) 50-1993 8,000-44,000 12,000-44,00040-50 2,800Aluminum (Al) 545-5500Sodium (Na) 858-18,000Chlorine (Cl) 79.06Ash81400-5000 71,000-80,000280-300Biomass - Forest Derived Biomass and Pulp and Paper Residues11ConstituentPulp and Paper SludgeDe-inkingpapersludge1Hydropulperrefuse2Mechanicalpulp millsludge3Kraftmillsludge4Recyclepaper millsludge5Pulp mill, other nonspecified pulp and papersludges6DioxinsNaphtalene 0.1-0.31,1,2,2,-Tetrachloroethane<0.3Tetrachloroethylene <0.3Trichloroethylene <0.3Bromoform <0.3Chloroform <0.3Benzene <0.1Chlorobenzene <0.1Ethylbenzene <0.1Styrene <0.1Toluene <0.1Notes:Blank cells indicate no data available.Black liquor solids (hardwood-softwood) arenot included in pulp and paper sludge category as described in the final rule.1Beauchamp (2002), Scott (1995), Gavrilescu(2008). Sulfur, ash, and two nitrogen values from Scott and Gavrilescu, rest ofthe data are from Beauchamp.2OAQPS (2010)3Environmental Sciences Division (1999)4Scott (1995)5Scott (1995)6Thacker et al. (2007), O'Brien (2001), Scott (1995). Dioxin values from Thacker et al.. Sulfur, ash and one nitrogen valuefrom Scott, rest of the data are from O'Brien.Biomass - Forest Derived Biomass and Pulp and Paper Residues12Exhibit 4: Comparative Impacts of WoodCombustion versus Alternative Primary FuelsPollutantWood Coal Distillate Fuel Oil Residual Fuel Oil Natural GasCombustion CombustionCombustionplusUpstream CombustionCombustionplusUpstream CombustionCombustionplusUpstream CombustionCombustionplusUpstream----------------------------- lb./MMBtu ---------------------------Criteria PollutantsPM2.5 - - - - - - - - -PM10 0.019 0.054 0.054 0.011 0.011 0.093 0.093 0.009 0.009PM, unspecified - - 0.246 - 0.012 - 0.012 - 0.004NOx 0.167 0.482 0.504 0.173 0.234 0.367 0.428 0.301 0.417VOCs - 0.006 0.014 0.001 0.363 0.002 0.367 0.009 0.524SOx 0.008 1.446 1.469 0.209 0.394 1.593 1.781 0.073 1.985CO 1.511 0.068 0.085 0.036 0.082 0.033 0.079 0.058 0.282Pb 1.33x10-48.93x10-69.19x10-64.60x10-65.61x10-65.80x10-55.90x10-5- 2.72x10-7Hg - 2.05x10-62.14x10-61.58x10-61.77x10-68.67x10-68.85x10-6- 7.18x10-8Greenhouse GasesCO2233.3 210.7 214.7 161.2 180.1 173.3 192.5 114.6 129.8CH4- 0.007 0.458 3.74x10-40.03 0.007 0.036 0.003 0.372N2O - 0.003 0.003 - 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.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### 4 Lifecycle Emissions Impacts: Use of forest derived biomass 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, Exhi bit 4 lists the quantities of the total cradle-to-gate emissions for these fuels based on typical proces ses in the United States in the late 1990s, with wood scrap combustion presented as an indicator of the emissions likely from the

combustion of wood debris. Note that th ere may be impacts associated with the processing of wood debris into useable fuel that are not accounted for in the values presented in Exhibit 4. In a ddition, there may be alternative uses (e.g., mulching) that are environmentally preferable to combustion.Biomass - Forest Derived Biomass and Pulp and Paper Residues

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### References

AF&PA. 2008, 48 th Annual Survey of Paper, Paperboard, and Pulp Capacity (American Forest & Paper Association, Washington, DC).

ASTSWMO. 2007, ASTSWMO 2006 Beneficial Use Survey Report (Association of State and Territorial Solid Waste Management Officials, Washington, DC).

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