Materials Characterization Paper 

In Support of the 

Final Rulemaking: 

Identification of Nonhazardous Secondary Materials That Are Solid Waste

Biomass - Forest Derived Biomass and Pulp and Paper Residues 

February 3, 2011

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

1. Definitions of Forest Derived Biomass and Pulp and Paper Residues 

The forest products industry generates large amounts 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 residues) 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 residues 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, furniture factories, and truss and pallet 

manufacturing (secondary mill residues). These materials 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 products. A separate materials 

characterization paper has been developed for this material. 

Another source of biomass fuels from the forest products industry is pulp and paper residuals, 

black liquor,2 and wastewater treatment sludges. Black liquor (which is not included in pulp and 

paper sludge category as described in the final rule and should be considered separately) is 

generated in the kraft process, which in 2000 accounted for 83 percent of domestic pulp 

production. Black liquor consists of lignin and pulping chemicals used to separate lignin from 

the cellulosic fraction of wood. Sludges, both primary and secondary, are produced from 

wastewater treatment of process effluents. Primary sludges originate from primary wastewater 

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

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

 1 Other materials are sometimes identified as Forest Product Industry (FPI)-derived fuels in the literature; 

these include wood products found in bales 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 materials characterization papers. In other cases, it is not 

clear whether the materials are already considered part of another material (e.g., OCC rejects) or are used as fuel 

with any frequency (e.g., tall oil). Public comments submitted by Michigan Biomass in response to the Advanced 

Notice of Proposed Rulemaking indicate that pallets, crate 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 and 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 considered a legitimate non-waste fuel because it meets the chemical and physical 

specifications of a traditional benchmark fuel. 
Biomass - Forest Derived Biomass and Pulp and Paper Residues 

2

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 Biomass and Pulp and Paper Residues Generated 

and Used 

(1) Sectors that Generate Forest Derived Biomass 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 Engineered Wood Product Manufacturing 

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

Generated: 

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

at 67.1 million tons3

, 41.9 million tons of which is available for recovery. This is 

consistent with Milbrandt (2005), who estimated total production at 62.4 million 

tons. McKeever (2004) estimated 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 Service’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 sludges (ITC 2002, Thacker 2007). 

• Gan (2007) estimates for forest residue a median total market price (including 

transport) of $40 per dry ton with a range 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 some 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 Derived Biomass and Pulp and Paper Residues: 

• Domestic primary mill residue production 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 decreased at an average annual rate of 0.7 

percent for the period from 2000 to 2007 (AF&PA 2008). 

• US timber harvest is expected to increase 24 percent by 2050 according to the 

Fifth Resources Planning Act Timber Assessment (Haynes and Skog 2002). This 

increase will be exclusively in the harvest of nonsawtimber trees. 

• Perlack et al. (2005) predict that by 2050 increases 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 

3

primary and secondary mill residues by 16 million tons. An additional 60 million 

tons of forest biomass may also be available should widespread fuel treatments 

for reducing fire hazards be implemented. 

3. Uses of Forest Derived Biomass 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) state 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 Corporation’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 Packaging International, 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 operations are combusted 

as fuel in pulping liquor recovery furnaces. These furnaces provide process 

energy and recover pulping agents (e.g., sodium 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 developed 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 material 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 residues (excluding black liquor) include hydro pulper refuse, 

kraft pulp fiber, OCC plant rejects, OCC rejects, paper and 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 as 
Biomass - Forest Derived Biomass and Pulp and Paper Residues 

4

burning approximately 3.2 million tons of biomass material per year that may or 

may not be forest-derived or pulp and paper residues6

 (EPA 2009). 

• It has been estimated that thermal oxidation 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 Derived Biomass and Pulp and Paper Residues:

• Logging residues left on harvested timberland help control erosion, replenish 

nutrients, and maintain soil productivity. It is unknown what fraction can be 

removed without disrupting these benefits, and 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 driven 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, liming agent, or mulch (Sippola et 

al. 2003, Thacker 2007). Around 11.7 percent had other beneficial uses, including 

as papermaking fiber, industrial absorbent, animal bedding, manufactured soil 

component, compost feedstock, landfill barrier cover (Zule et al. 2007), acid mine 

drainage control cover, building 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 paper 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 and Pulp and Paper Residues landfilled: 

• Of the residues described in this section, 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, ITC 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 papers) rather than forest-derived biomass. 

5

 Although we report forest-derived biomass and pulp 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 characterized as bio-liquids or biomass. 
Biomass - Forest Derived Biomass and Pulp and Paper Residues 

5

(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 and 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 for Forest Derived Biomass and Pulp and 

Paper Residues 

(1) Types of Units Using Forest Derived Biomass 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 wood 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 combusted 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 Biomass and Pulp and Paper Residues: 

• Logging and primary milling residues may 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 

6

• Black liquor undergoes a series of concentrating 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 then to around 65 percent by a directcontact evaporator or indirect-contact concentrator (EPA 1995, EPA 2002). 

• Pulp and paper mill sludges typically undergo mechanical dewatering before 

being combusted as fuel, with minimum solids content of around 40 percent 

needed for sustained combustion (Sell 1992, Caputo and Pelagagge 2001). Some 

sludges are dried to 70 to 95 percent solids (Thacker 2007). 

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

Fuel:

According to state responses 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 pre-approved status, suggesting that a case-bycase approval process for designation of beneficial use is not necessary for this use 

(ASTSWMO 2007, p.B-25). In addition, Michigan reports that in at least one 

instance the use of pulp and paper residues as fuel has been approved as a beneficial 

use. 

As of September 2006, approximately 50 percent of states had renewable fuels 

portfolio standards requiring that varying percentages of power generated within the 

individual states come from alternative fuels (including biomass) by a designated 

future date; several more states have enacted such regulations since then (DOE 

2006).7

 

5. Forest Derived Biomass and Pulp and Paper Residues Composition and Impacts 

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

• The heating values of forest derived biomass and pulp and paper residues depend 

upon moisture content. 

• The heating value for dry (0 percent moisture) woody materials8

 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 heating 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 sludges 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 reference does not always specify which types of biomass are included, 

however, it is likely that woody biomass is included. For example, Nevada specifies “wood”.

8

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

7

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 btu/lb), respectively. 

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

• Exhibit 2 presents the chemical composition 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 derived 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 other traditional fuels, even bituminous coal, 

with a range of 2-80 ppm. 

Exhibit 2: Constituents of Forest Derived Biomass 

Constituent

Forest Derived Biomass 

Biomass1

(not 

specified) 

Virgin 

Wood2

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 

8

• 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 concentrations for several types of pulp and 

paper sludge for which data were available. As an illustration of the differences 

in constituent concentrations across different types of sludges, the concentration 

of sulfur is considerably higher in black liquor solids than the rest of the sludge 

sub-types. 

(3) Emissions Impacts of Using Forest Derived 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 associated with the combustion of conventional 

fossil fuels, as summarized in Exhibit 2.9

 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. 

Therefore, they fall within the range of typical fuels. The data in Exhibit 2 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.10 

• Public comments from the International Paper Products Corporation indicate that 

emissions from the proper combustion of paper derived fuel (PDF) are cleaner 

than emissions associated with the combustion 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, SO2 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 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 

 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 

9

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

(Biomass Energy Resource Center). 
Biomass - Forest Derived Biomass and 

10

Exhibit 3: Constituents of Pulp and Paper Sludge 

Constituent

Pulp and Paper Sludge 

De-inking 

paper 

sludge1 

Hydro 

pulper 

refuse2 

Mechanical 

pulp mill 

sludge3 

Kraft 

mill 

sludge4 

Recycle 

paper mill 

sludge5 

Pulp mill, other nonspecified pulp and paper 

sludges6 

-----Values in parts per million (ppm)-----

Cadmium (Cd) <1 0.3 0.3-1.38 0 Arsenic (As) <10 1.64 Chromium (Cr) 3.8-5.6 2.37 2.5-14.7 0.4 Mercury (Hg) 0-0.6 Nickel (Ni) <10 10.52 4.3-16.0 0.4 Boron (B) <5 0.5 Potassium (K) 94-214 650-5,290 151 Selenium (Se) <2 Molybdenum (Mo) <2 Manganese (Mn) 13-27 173.88 27 Magnesium (Mg) 406-840 364 Iron (Fe) 261-595 143 Copper (Cu) 92-130 1.6-37.0 5 Cobalt (Co) <2 0.5 Lead (Pb) <20 2.03 <1.5-7.06 5 Zinc (Zn) 17-61 22.0-114 31 Antimony (Sb) 0.79 Beryllium (Be) 0.032 Fluorine (F) 24.13 Phosphorus (P) 331.38 1,528-7,950 57 Sulfur (S) 5-20 8,000-

10,000 

20-30 

Calcium (Ca) 6014-

10612 

 4,080-12,800 76,292 

Nitrogen (N) 50-1993 8,000-44,000 12,000-

44,000 

40-50 2,800 

Aluminum (Al) 545-5500 Sodium (Na) 858-18,000 Chlorine (Cl) 79.06 Ash8 1400-5000 71,000-

80,000 

280-300 
Biomass - Forest Derived Biomass and 

11

Constituent

Pulp and Paper Sludge 

De-inking 

paper 

sludge1 

Hydro 

pulper 

refuse2 

Mechanical 

pulp mill 

sludge3 

Kraft 

mill 

sludge4 

Recycle 

paper mill 

sludge5 

Pulp mill, other nonspecified pulp and paper 

sludges6 

Dioxins Naphtalene 0.1-0.3 1,1,2,2,-Tetrachloroethane 

<0.3 

Tetrachloroethylene <0.3 Trichloroethylene <0.3 Bromoform <0.3 Chloroform <0.3 Benzene <0.1 Chlorobenzene <0.1 Ethylbenzene <0.1 Styrene <0.1 Toluene <0.1 Notes: Blank cells indicate no data available. Black liquor solids (hardwood-softwood) are not included in pulp and paper sludge category as described in the final rule. 1 Beauchamp (2002), Scott (1995), Gavrilescu (2008). Sulfur, ash, and two nitrogen values from Scott and Gavrilescu, rest of 

the data are from Beauchamp. 

2 OAQPS (2010) 3 Environmental Sciences Division (1999) 4 Scott (1995) 5 Scott (1995) 6 Thacker et al. (2007), O'Brien (2001), Scott (1995). Dioxin values from Thacker et al.. Sulfur, ash and one nitrogen value 

from Scott, rest of the data are from O'Brien. 
Biomass - Forest Derived Biomass and 

12

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

Pollutant 

Wood Coal Distillate Fuel Oil Residual Fuel Oil 

Combustion Combustion 

Combustion 

plus 

Upstream Combustion 

Combustion 

plus 

Upstream Combustion 

Combustion 

plus 

Upstream Co

----------------------------- 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 GasesCO2 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. 
Biomass - Forest Derived Biomass and Pulp and Paper Residues 

 

13

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, Exhibit 4 lists the quantities of the total cradle-to-gate 

emissions for these fuels based on typical processes 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 there 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 addition, there may be alternative uses (e.g., mulching) that are 

environmentally preferable to combustion. 
Biomass - Forest Derived Biomass and Pulp and Paper Residues 

 

14

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