JEPA
United States
Environmental Protection
Agency
safc5@aw*:ii
ProfileOft
Lumber And
Industry i
NOTEBOOKS
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
Message from the Administrator
Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are hi demand
throughout the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold hi your hand is the result.
These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that - in industry after industry, community after community ~
environmental protection and economic prosperity go hand in hand.
Carol M. Brownor
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
-------
Lumber and Wood Products
Sector Notebook Project
EPA/310-R-95-006
EPA Office of Compliance Sector Notebook Project
Profile of the Lumber and Wood Products Industry
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-048273-9
SIC Code 24
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
This report is one in a series of volumes published by the U.S. Environmental
Protection Agency (EPA) to provide information of general interest regarding
environmental issues associated with specific industrial sectors. The documents
were developed under contract by Abt Associates (Cambridge, MA), and Booz-Allen
& Hamilton, Inc. (McLean, VA). This publication may be purchased from the
Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included at the end of this
document.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be
directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as
public and academic libraries, Federal, State, local, and foreign governments, and the
media. For further information, and for answers to questions pertaining to these
documents, please refer to the contact names and numbers provided within this
volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e
Bulletin Board and via Internet on the Enviro$en$e World Wide Web.
Downloading procedures are described in Appendix A of this document.
Cover photograph by Steve Delaney, U.S. EPA.
September 1995
SIC Code 24
-------
Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:
Seth Heminway, Sector Notebook Project Coordinator
US EPA, Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017 fax (202) 564-0050
E-mail: heminway:seth@epamail.epa.gov
Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
•R-95-010.
•R-95-011.
•R-95-012.
-R-95-013.
-R-95-014.
•R-95-015.
•R-95-016.
•R-95-017.
•R-95-018.
•R-97-001.
R-97-002.
R-97-003.
R-97-004.
R-97-005.
R-97-006.
R-97-007.
R-97-008.
R-97-009.
R-97-010.
EPA/310-B-96-003.
Industry
Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
*Air Transportation Industry
Ground Transportation Industry
* Water Transportation Industry
Metal Casting Industry
Pharmaceutical Industry
Plastic Resin and Man-made Fiber Ind.
*Fossil Fuel Electric Power Generation Ind.
*Shipbuilding and Repair Industry
Textile Industry
*Sector Notebook Data Refresh, 1997
Federal Facilities
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway
Jim Edwards
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017
564-2461
* Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting
-------
Lumber and Wood Products
Sector Notebook Project
LUMBER AND WOOD PRODUCTS
(SIC 24)
TABLE OF CONTENTS
Page
..vi
EXHIBITS INDEX
LIST OF ACRONYMS viii
I.
n.
ni.
IV.
Industry Size and Distribution 5
Economic Trends 9
V.
INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
LA. Summary of the Sector Notebook Project 1
I.B. Additional Information 2
INTRODUCTION TO THE LUMBER AND WOOD PRODUCTS INDUSTRY 4
II.A. Introduction, Background, and Scope of the Notebook 4
n.B. Characterization of the Lumber and Wood Products Industry ..5
H.B.1
H.B.2.
INDUSTRIAL PROCESS DESCRIPTION 10
m.A. Industrial Processes in the Lumber and Wood Industry 11
IH.B. Raw Material Inputs and Pollution Outputs 31
IH.C Management of Chemicals in Wastestream 38
CHEMICAL RELEASE AND TRANSFER PROFILE 40
IV.A. EPA Toxic Release Inventory for the Lumber and Wood
Products Industry 43
IV.B. Summary of Selected Chemicals Released 48
IV.C. Other Data Sources 54
rV.D. Comparison of Toxic Release Inventory Between Selected
Industries 55
POLLUTION PREVENTION OPPORTUNITIES 58
SIC Code 24
IV
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
LUMBER AND WOOD PRODUCTS
(SIC 24)
TABLE OF CONTENTS (CONT'D)
Page
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS 67
VI.A. General Description of Major Statutes 67
VLB. Industry Specific Requirements 78
VI.C. Pending and Proposed Regulatory Requirements 83
VII. COMPLIANCE AND ENFORCEMENT HISTORY.... £5
VILA. Lumber and Wood Products Industry Compliance
History 89
VII.B. Comparison of Enforcement Activity Between Selected
Industries 91
VII.C. Review of Major Legal Actions 96
VII.C.l. Review of Major Cases 96
VII.C.2. Supplemental Environmental Projects (SEPs) 97
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 99
VIII.A. Sector-Related Environmental Programs and Initiatives 99
VIII.B. EPA Voluntary Programs 100
VIII.C. Trade Association/Industry Sponsored Activity 104
VIII.C.l. Environmental Programs 104
VIII.C.2. Summary of Trade Associations 105
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY HI
September 1995
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
Exhibit 11
Exhibit 12
Exhibit 13
Exhibit 14
Exhibit 15
Exhibit 16
Exhibit 17
LUMBER AND WOOD PRODUCTS
(SIC-24)
EXHIBITS INDEX
Page
Industry Facility Size Distribution - 1992 6
Geographic Distribution of Industry Total Number of Lumber and
Wood Facilities per State 6
Geographic Distribution of Industry Breakdown of Lumber
and Wood Facilities by State 7
Largest U.S. Lumber and Wood Products Facilities
by Capacity (1993)
.8,9
Example Flow Diagram for a Lumber Production Facility .................... 12
Veneer Dryer (Longitudinal) [[[ I7
Example Flow Diagram of Veneer and Plywood Production ............... 19
Reconstituted Wood Panel Process Flow .................................................. 21
Schematic of Conventional Triple-Pass Drum Dryer ............................. 22
Schematic of Multi-Opening Board Press .................................................. 24
Example Flow Diagram for a Two-Cylinder CCA
Pressure-Treating Facility
29
Drip Pad with Liner 30
Process Materials Inputs and Pollution Outputs 32
Source Reduction and Recycling Activities for SIC 24 39
Top 10 TRI Releasing Lumber and Wood Product Facilities
(SIC 24 only)
.44
Top 10 TRI Releasing Lumber and Wood Product Facilities 44
TRI Reporting Lumber and Wood Product Facilities
(SIC 24) by State 45
SIC Code 24
VI
-------
Sector Notebook Project
Lumber and Wood Products
LUMBER AND WOOD PRODUCTS
(SIC-24)
EXHIBITS INDEX (CONT'D)
Page
Exhibit 18 Releases for Lumber and Wood Products (SIC 24) in TRL
by Number of Facilities 46
Exhibit 19 Transfers for Lumber and Wood Products (SIC 24) in TRL
by Number of Facilities 47
Exhibit 20 Pollutant Releases (Short Tons/Year) 54
Exhibit 21 Summary of the 1993 TRI Data 56
Exhibit 22 Toxic Release Inventory Data for Selected Industries 57
Exhibit 23 Five Year Enforcement and Compliance Summary for the
Lumber and Wood Industry 90
Exhibit 24 Five Year Enforcement and Compliance Summary for Selected
Industries 92
Exhibit 25 One Year Enforcement and Compliance Summary for Selected
Industries 93
Exhibit 26 Five Year Inspection and Enforcement Summary by
Statute for Selected Industries 94
Exhibit 27 One Year Inspection and Enforcement Summary by
Statute for Selected Industries 95,
Exhibit 28 Supplemental Environmental Projects 98
Exhibit 29 Lumber and Wood Products Facilities Participating in the
33/50 Program 101
September 1995
vn
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
LUMBER AND WOOD PRODUCTS
(SIC 24)
LIST OF ACRONYMS
ACZA - Ammoniacal Copper Zinc Arsenate
AFS - AIRS Facility Subsystem (CAA database)
ABRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
CAA - Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CCA - Chromated Copper Arsenate
CERCLA- Comprehensive Environmental Response, Compensation and
Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO- Carbon Monoxide
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
EPA - United States Environmental Protection Agency
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HB - Hardboard
IDEA - Integrated Data for Enforcement Analysis (Enforcement Database)
LDR - Land Disposal Restrictions (RCRA)
LVL - Laminated Veneer Lumber
MACT - Maximum Achievable Control Technology (CAA)
MDI - Methylenediphenyl Diisocyanate
MDF - Medium density Fiberboard
NAAQS - National Ambient Air Quality Standards (CAA)
NaOH - Sodium Hydroxide
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency Plan
NESHAP - National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards (CAA)
NOx - Nitrous Oxides
NPDES - National Pollution Discharge Elimination System (CWA)
OAR - Office of Air and Radiation
OPA - Oil Pollution Act
OECA - Office of Enforcement and Compliance Assurance
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSB - Oriented Strand Board
OSW - Office of Solid Waste
OSWER - Office of Solid Waste and Emergency Response
OW - Office of Water
P2- Pollution Prevention
SIC Code 24
Vlll
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
LUMBER AND WOOD PRODUCTS
(SIC 24)
LIST OF ACRONYMS (CONT'D)
PB - Particleboard
PCP - Pentachlorophenol
PCS - Permit Compliance System (CWA Database)
PF - Phenol-Formaldehyde
PM - Particulate Matter
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SDWA - Safe Drinking Water Act
SOX - Sulfur Oxides
TGNMO Total Gaseous Nonmethane Organics
TRI - Toxic Release Inventory
TRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
UF - Urea-Formaldehyde
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
September 1995
IX
SIC Code 24
-------
-------
Sector Notebook Project
Lumber and Wood Products
LUMBER AND WOOD PRODUCTS
(SIC 24)
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
LA. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air,
water, and land pollution are an inevitable and logical supplement to
traditional single-media approaches to environmental protection.
Environmental regulatory agencies are beginning to embrace
comprehensive, multi-statute solutions to facility permitting,
enforcement and compliance assurance, education/outreach, research,
and regulatory development issues. The central concepts driving the
new policy direction are that pollutant releases to each environmental
medium (air, water, and land) affect each other, and that
environmental strategies must actively identify and address these
inter-relationships by designing policies for the "whole" facility. One
way to achieve a whole facility focus is to design environmental
policies for similar industrial facilities. By doing so, environmental
concerns that are common to the manufacturing of similar products
can be addressed in a comprehensive manner. Recognition of the need
to develop the industrial "sector-based" approach within the EPA
Office of Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of Compliance
within the Office of Enforcement and Compliance Assurance (OECA)
to provide its staff and managers with summary information for
eighteen specific industrial sectors. As other EPA offices, States, the
regulated community, environmental groups, and the public became
interested in this project, the scope of the original project was
expanded. The ability to design comprehensive, common sense
environmental protection measures for specific industries is
dependent on knowledge of several inter-related topics. For the
purposes of this project, the key elements chosen for inclusion are:
general industry information (economic and geographic); a description
of industrial processes; pollution outputs; pollution prevention
opportunities; Federal statutory and regulatory framework; compliance
history; and a description of partnerships that have been formed
between regulatory agencies, the regulated community, and the public.
For any given industry, each topic listed above could alone be the
subject of a lengthy volume. However, in order to produce a
September 1995
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
manageable document, this project focuses on providing summary
information for each topic. This format provides the reader with a
synopsis of each issue, and references where more in-depth
information is available. Text within each profile was researched from
a variety of sources, and was usually condensed from more detailed
sources pertaining to specific topics. This approach allows for a wide
coverage of activities that can be further explored based upon the
citations and references listed at the end of this profile. As a check on
the information included, each notebook went through an external
review process. The Office of Compliance appreciates the efforts of all
those that participated in this process and enabled us to develop more
complete, accurate, and up-to-date summaries. Many of those who
reviewed this notebook are listed as contacts in Section IX and may be
sources of additional information. The individuals and groups on this
list do not necessarily concur with all statements within this notebook.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update
the notebooks and will make these updates available both in hard copy
and electronically. If you have any comments on the existing
notebook, or if you would like to provide additional information,
please send a hard copy and computer disk to the EPA Office of
Compliance, Sector Notebook Project, 401 M St., SW (2223-A),
Washington, DC 20460. Comments can also be uploaded to the
Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web for
general access to all users of the system. Follow instructions in
Appendix A for accessing these data systems. Once you have logged in,
procedures for uploading text are available from the on-line
Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the
relative national occurrence of facility types that occur within each
sector. In many instances, industries within specific geographic regions
or States may have unique characteristics that are not fully captured in
these profiles. For this reason, the Office of Compliance encourages
State and local environmental agencies and other groups to
supplement or re-package the information included in this notebook to
include more specific industrial and regulatory information that may
be available. Additionally, interested States may want to supplement
the "Summary of Applicable Federal Statutes and Regulations" section
SIC Code 24
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
with State and local requirements. Compliance or technical assistance
providers may also want to develop the "Pollution Prevention" section
in more detail. Please contact the appropriate specialist listed on the
opening page of this notebook if your office is interested in assisting us
in the further development of the information or policies addressed
within this volume.
If you are interested in assisting in the development of new notebooks
for sectors not covered in the original eighteen, please contact the
Office of Compliance at 202-564-2395.
September 1995
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
n.
INTRODUCTION TO THE LUMBER AND WOOD PRODUCTS INDUSTRY
II.A. Introduction, Background, and Scope of the Notebook
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition
of the lumber and wood products industry. The type of facilities
described within the document are also described in terms of their
Standard Industrial Classification (SIC) codes. Additionally, this
section contains a list of the largest companies in terms of sales.
The lumber and wood products industry includes establishments
engaged in cutting timber and pulpwood; sawmills, lath mills, shingle
mills, cooperage stock mills (wooden casks or tubs), planing mills,
plywood mills; and establishments engaged in manufacturing finished
articles made entirely or mainly of wood or related materials such as
reconstituted wood panel products manufacturers. The categorization
corresponds to the Standard Industrial Classification (SIC) code 24
established by Department of Commerce's Bureau of the Census to
track the flow of goods and services within the economy. It should be
noted that silviculture (development and care of forests) and the
preparation of forested areas for logging is covered by SIC 08 (forestry)
and is not addressed in this industry profile.
In this profile, the industry's processes are divided into four general
groups: logging timber; producing lumber; panel products and wood
preserving. The Bureau of the Census estimates that in 1992,
employment in these principal categories totaled approximately 306,700
(See Exhibit 1 for facility employment size distribution). This does not
include the additional employment generated by the wood container,
structure wood member, wood kitchen cabinet, and wood
building/mobile home sectors. Shipments increased less than one
percent in 1993, to an estimated $78.1 billion. Sawmills and planing
mills (SIC 242) accounted for $24.8 billion (31 percent) of industry
shipments in 1993. Logging (SIC 241) added an additional $15.6 billion
(17.8 percent).
The Department of Commerce provides the following three-digit
breakout for lumber and wood products industries in SIC 24:
SIC 241 - Logging
SIC 242 - Sawmills and Planing Mills
SIC 243 - Millwork, Veneer, Plywood, and Structural Wood
Members
SIC 244 - Wood Containers
SIC 245 - Wood Buildings and Mobile Homes
SIC Code 24
September 1995
-------
Sector Notebook. Project
Lumber and Wood Products
SIC 249
Miscellaneous Wood Products.
The main end use market for the industry's products is the new
construction and remodeling sectors.
This profile covers logging, sawn lumber production, panel products
including veneer and plywood manufacture and reconstituted wood
panel manufacture (which includes particleboard (PB), hardboard (HB),
medium density fiberboard (MDF), and oriented strand board(OSB)),
engineered lumber, and wood preserving. Each of these are discussed
in greater detail later in the profile. This profile does not address
production processes, pollution outputs, or regulatory information for
the following three-digit industries contained in SIC 24: Wood
Containers (SIC 244), Wood Buildings and Mobile Homes (SIC 245),
and some areas of Miscellaneous Wood Products (SIC 249).
II.B. Characterization of the Lumber and Wood Products Industry
The discussion of the characterization of the lumber and wood
products industry is divided into the following topics: industry size and
geographic distribution; identification of the largest U.S. facilities in the
industry by capacity; and industry economic trends.
II.B.l. Industry Size and Distribution
Variation in facility counts occur across data sources due to many
factors, including reporting and definition differences. This document
does not attempt to reconcile these differences, but rather reports the
data as they are maintained by each source.
Geographic Distribution
Most of the wood products industry is concentrated in the Pacific
Northwest and the Southeast. However, concentrations are also found
across the Midwest, the Northeast, and in Appalachia (See Exhibits 2
and 3). Approximately 1/3 of the U.S. is forested. Of this forested area,
two-thirds (480 million acres) contain at least 20 cubic feet of
commercially usable wood per year per acre, the threshold for
determining whether timberland could be commercially productive.
The area east of the Mississippi still contains a significant amount of
forested acreage; 155 million acres are in the Northern States and 195
million acres are in the South. About 130 million acres of forested land
is in Western States. Exhibit 4 illustrates the largest lumber and wood
products facilities in the U.S. by capacity.
September 1995
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 1
Industry Facility Size Distribution -1992
Type of Facility
SIC 2411 -Logging
SIC 2421 -Lumber
SICs 2435 & 2436-
Hardwood, Softwood
Plywood, Veneer
SIC 2491 -Wood
Preserving
SIC 2493 -
Reconstituted Wood
Products
Facilities
with 1 to 19
employees
12,283
4,400
147
307
108
Facilities
with 20 to 99
employees
691
1,283
208
168
80
Facilities with
100 or more
employees
36
321
164
11
100
Total
13,010
6,004
519
486
288
Source: Based on lyy^i aureau of me census uata.
Exhibit 2
Geographic Distribution of Industry
Total Number of Lumber and Wood Products Facilities per State*
Source: Based on 1987 Bureau of the Census Data. 1992 Bureau of the Census Data on
State breakdown was not available at the time of publication.
*Note: Exhibit represents all industries within SIC 24.
SIC Code 24
September 1995
-------
Sector Notebook.Project
Lumber and Wood Products
Exhibits
Geographic Distribution of Industry
Breakdown of Lumber and Wood Facilities by State
Type of Facility
Number of Facilities Per State
Logging
AL-957, AK-37, AR-403, CA-525, FL-346, GA-796, ID-321, KY-95,
LA-413, ME-439, MI-341, MN-176, MS-531, MT-312, NH-130, NH-130,
NY-209, NC-677, OH-128, OR-1,293, PA-257, SC-559, TN-128, TX-297,
VA-444, WA-597, WV-185, WI-384
Sawmills and
Planning Mills
AL-212, AZ-17, AR-218, CA-278, CO-48, CT-34, FL-94, GA-216, ID-100,
IL-75, IN-155, KY-185, LA-104, ME-141, MD-58, MA-89, MI-219,
MN-96, MS-213, MO-237, MT-68, NH-83, NM-27, NY-231, NC-554,
OH-172, OK-50, OR-309, PA-448, SC-126, SD-17, TN-345, TX-116,
UT-26, VT-78, VA-370, WA-381, WV-188, WI-206, WY-28
Millwood, Plywood
and Structural
Members
AL-158, AZ-146, AR-85, CA-1,145, CO-140, CT-122, FL-661, GA-260,
ID-66, IL-224, IN-213, IA-54, KS-70, KY-78, LA-77, ME-31, MD-86,
MA-172, MI-192, MN-165, MS-73, MO-144, MT-30, NE-47, NV-42,
NH-47, NJ-165, NM-62, NY-378, NC-294, OH-225, OK-49, OR-298,
PA-315, RI-28, SC-105, SD-21, TN-153, TX-412, UT-82, VT-30, VA-185,
WA-273, WV-26, WI-206
Wood Containers
AL-56, AR-39, CA-204, FL-37, GA-69, IL-13, IN-103, KY-71, MI-144,
MN-36, MS-39, MO-85, NJ-46, NY-82, NC-80, OH-172, OR-26, PA-155,
SC-38, TN-87, TX-85, VA-54, WA-30, WI-83
Wood Buildings and
Mobile Homes
AL-46, AZ-20, CA-87, CO-11, DE-2, FL-68, GA-53, ID-13, IL-25, IN-55,
KS-12, ME-12, MD-13, MA-18, MI-34, MN-20, MS-12, MO-21, NE-7,
NH-20, NY-27, NC-51, OH-36, OR-23, PA-72, TN-32, TX-74, VA-31,
WA-18, WI-34
Miscellaneous Wood
Products
AL-113, AR-84, CA-432, FL-161, GA-128, ID-43, IL-147, IN-96, IA-27,
KY-46, LA-58, ME-91, MD-36, MA-93, MI-141, MN-79, MS-96, MO-102,
NH-72, NJ-71, NM-16, NY-210, NC-202, OH-143, OK-26, OR-159,
PA-181, SC-68, TN-88, TX-195, VT-115, WA-123, WV-36, WI-119
Source: Based on 1987 Bureau of the Census Data.*
*1992 Bureau of Census Data on State breakdown was not available at the time of publication.
September 1995
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 4
Largest U.S. Lumber and Wood Products Facilities by Capacity (1993)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Lumber Production
Weyerhaeuser Co.
Georgia-Pacific Corp.
Louisiana-Pacific Corp.
Sierra Pacific Industries
International Paper Co.
Boise Cascade Corp.
Pope &Talbot Inc.
MacMillan Bloedel Ltd.
WTD Industries Inc.
Simpson Timber Co.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Softwood Plywood
Georgia-Pacific Corp.
Willamette Industries Inc.
Boise Cascade Corp.
Louisiana-Pacific Corp.
Roseburg Forest Products Co.
Weyerhaeuser Co.
Champion International
International Paper Co.
Stimson Lumber Co.
Stone Forest Industries Inc.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Softwood Veneer
Scotch Plywood Co. of Alabama
Stone Forest Industries Inc.
Freres Lumber Co. Inc.
Sun Studs Inc.
Plum Creek Manufacturing, L.P.
Hunt Plywood Co. Inc.
Omak Wood Products, Inc.
Roseburg Forest Products
Green Veneer Inc.
WTD Industries Inc.
1.
2.
3.
4.
5.
6.
7.
8.
9.
OSB/Waferboard
Louisiana-Pacific Corp.
Potlatch Corp.
Georgia-Pacific Corp.
Weyerhaeuser Co.
J.M. Huber Corp.
Norbord Industries
Roy O. Martin Lumber Co. Inc.
International Paper Co.
Langdale Forest Products Co.
1.
4.
5.
6.
7.
8.
9.
10.
Particleboard
Georgia-Pacific Corp.
Willamette Industries Inc.
Weyerhaeuser Co.
Louisiana-Pacific Corp.
Temple-Inland Forest
Products Corp.
Roseburg Forest Products Co.
Masonite Corp.
Allegheny Particleboard Corp.
Boise Cascade Corp.
Timber Products Co.
6.
7.
8.
9.
10.
Medium-density Fiberboard
Willamette Industries Inc.
Louisiana-Pacific Corp.
Medite Corp.
Masonite Corp.
Plum Creek Manufacturing, L.P.
Georgia-Pacific Corp.
Sierra-Pine, Ltd.
Weyerhaeuser Co.
Norbord Industries
Bassett Industries
Source: American Forest & Paper Association, Wood Technology's 1994-95 North American Factbook.
SIC Code 24
September 1995
-------
Sector Notebook. Project
Lumber and Wood Products
Exhibit 4 (cont'd)
Largest U.S. Lumber and Wood Products Facilities by Capacity (1993)
3.
5.
1.
2.
3.
4.
5.
6.
7.
8.
Hardboard
Georgia-Pacific Corp.
Masonite Corp.
Weyerhaeuser Co.
Wood Fiber Industries Inc.
Louisiana-Pacific Corp.
Stimson Lumber Co.
Bvanite Fiber Corp.
Dee Forest Products Inc.
Laminated Veneer
Lumber, I-joists
Louisiana-Pacific Corp.
Willamette Industries Inc.
Georgia-Pacific Corp.
Tecton Laminates
South Coast Lumber Co.
1.
1.
1.
Parallel, Laminated Strand
Lumber
Trus Joist MacMillian
Glulam Beams
Willamette Industries Inc.
Anthony Forest Products Co.
Panelboard
Georgia-Pacific Corp.
Composite Panels
Oregon Strand Board Co.
Source: American Forest & Paper Association, Wood Technology's 1994-95 North American Factbook.
II.B.2. Economic Trends
The lumber and wood products industry is heavily dependent upon
the health of the U.S. residential construction and household furniture
industries. Lumber and wood product shipments increased less than
one percent in 1993 and this low level of growth is expected to continue
in 1994. Domestic wood products shipments over the next five years
are expected to remain constant.
Since the mid-1980's, timber harvests from publicly-owned lands have
declined by more than 50 percent. The decline is due to new land
management policies by the Federal government that have reduced the
amount of land available for harvesting.
According to the Hardwood Plywood and Veneer Association, there
has been a substantial decline in the use of hardwood plywood
prefinished wall paneling due to shifts in consumer preference, a
decline in promotion and advertising by major manufacturers, changes
in the cost of plywood paneling related to gypsum wallboard, and the
September 1995
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
public's concern about real or perceived formaldehyde releases from
wall paneling. With respect to reconstituted wood panel products
shipments of PB, OSB, and MDF are all increasing rapidly. U.S.
shipments of MDF were at record levels in 1993.
The engineered lumber sector of the industry (reconstituted wood
substitutes for sawn lumber), is currently seeing a rapid rise in
production. The production of glulam beams and laminated veneer
lumber (LVL), two types of engineered lumber, is increasing rapidly
and this increased growth is expected to continue. By 2003, the North
American output of LVL is expected to reach 98 million ft3 (the
American Plywood Association's production estimate for LVL in 1995
is 33 million ft3).
SIC Code 24
10
September 1995
-------
Sectoi Notebook Project
Lumber and Wood Products
HI. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the lumber
and wood products industry, including the materials and equipment
used, and the processes employed. The section is designed for those
interested in gaining a general understanding of the industry, and for
those interested in the inter-relationship between the industrial
process and the topics described in subsequent sections of this profile —
pollutant outputs, pollution prevention opportunities, and Federal
regulations. This section does not attempt to replicate published
engineering information that is available for this industry. Refer to
Section IX for a list of reference documents that are available.
This section specifically contains a description of commonly used
production processes, associated raw materials, the by-products
produced or released, and the materials either recycled or transferred
off-site. This discussion, coupled with schematic drawings of the
identified processes, provide a concise description of where wastes may
be produced in the process. This section also describes the potential fate
(air, water, land) of these waste products.
III.A. Industrial Processes in the Lumber and Wood Industry
This section describes the major processes used by the lumber and
wood products industry. It is divided into the following sections:
logging, sawn lumber, paneling (including veneer and plywood and
reconstituted wood panel products), engineered lumber, and wood
preserving. Information for these descriptions was obtained from a
variety of sources including Characterization of Manufacturing
Processes, Emissions, and Pollution Prevention Options for the
Composite Wood Industry (Martin and Northeim, 1995), Forest
Products and Wood Science (Haygreen and Bowyer, 1989), and Guide to
Pollution Prevention: Wood Preserving Industry (U.S. EPA, 1993).
September 1995
11
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 5
Example Flow Diagram For a Lumber Production Facility
CO.VOC.
NOX.SOX,
FM
* BO1
L_ (BCHLER) •*
1 STEAM
KO2
(DHYWtN) *
FM
I
1 CO2 *
-- (CYCLONE)
FUGITIVE
EMISSIONS ^
SAW ROUGH
(SAWMILL) LUMBER
4
,rY!:?nf.n ~i WOOD WASTE WOOD WAS
1
^ SILO ROUGH
f
^ SORTER/
DRIED LUMBER
^ SHAVINGS
^
V
1 | To Customer || \ — ( TRWBLOCKS (PLANER MILL) p
CO3
(CYCLONE)
FUGITIVE
EMISSIONS 1
1 ] ToCusta
PLANED
LUMBER
PURCH/
^ CHIPS CH1 I11MB
^ (CHIHHhH) 1
I ^lj
mor ||~~\.,,. I \. •-».".«" "-•- •
TRT ^ I
(TREATMENT PLANT) ^
TREATEDLUMBER I
f T
^^- To Customer 1 \__
(sxy §7®' — cr A
TE ^ sain
ico, voc,
NOX, SOX,
PM
_ KO1 I
DHY KUN)
UNTREATED ^1 TnOietnmor 1 \
VSED
ER
FM
'
SANDERDUST ^^ CO4 _J
NG) ^ (CYCLONt)
FUGITIVE
EMISSIONS
A f
| To Customer || V_, | To Customer [| V_, 1 1 To Customer || V^
®®~ (53®'^-®-' C5>®
{SKsT1"®"1 @© C2X91 — er
Logging
Source: Southern Lumber Manufacturing Association, 1995.
Timber harvesting may be accomplished by either manual or
mechanical means. However, the traditional methods of hand sawing
or ax use are almost never used. Chain saws powered by gasoline
engines or large felling machines are currently used to cut down
SIC Code 24
12
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
standing trees. The felling machines use hydraulically-activated shears
that cut the tree at its base and transport it to a collection point. The
logs are transported by motorized cable or by tractor to larger collection
areas for transportation (usually by motor trucks or water) to the
sawmill.
Sawn Lumber
Sawn lumber is softwood or hardwood trimmed at a sawmill and
destined for a future use such as construction, industrial, or furniture
products. Most of the commercially important softwood species such
as Southern Yellow Pine, Western Pines, Western Hemlock, Spruce,
and Douglas Fir grow in the South or West. Softwood boards are used
primarily for framing light construction such as homes, schools,
churches, and farm buildings. Hardwood species such as Maple and
Oak, are grown and processed mainly in the Eastern portion of the U.S.
and are used for flooring, furniture, and crating.
Exhibit 5 illustrates the lumber production process. Logs are delivered
to sawmills from the forest and stored in ponds or on land. Most wood
is stored on land. Logs are sometimes stored at intermediate points
between the forest and the sawmill. If stored on land, the logs are
usually sprayed with water to keep them moist and prevent cracking.
The raw logs are debarked and then cut into cants (partially cut
lumber), which are trimmed into raw lumber. As the logs are
debarked, bark is used as hog fuel for boilers or sold as mulch.
Shavings, sawdust, and chips can also be used at paper mills and
reconstituted wood panel manufacturing plants.
The cants are cut to specific lengths or finished further depending on
the final destination of the lumber product. Most lumber is dried to a
specific moisture content (conditioned) through air or kiln drying. Air
drying, which entails stickering (spacing) and stacking the cut lumber
in open storage areas, usually requires several months to a few years.
Kiln drying is more time efficient because it uses controlled air flow
within a vented closed chamber to quickly dry the lumber to a specified
moisture content. Whether lumber is air- or kiln-dried depends upon
variables such as the moisture content of the species and the humidity
of the region.
Sawmills frequently perform surface protection operations to protect
lumber against sapstaining that may occur during temporary storage.
Sapstains do not attack the structural components of the wood but do
affect the surface, coloring it with dark blue or black stains. This
discoloration is often objectionable to the buyer and may decrease the
value of the wood and its acceptance of finishes.
September 1995
13
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Surface protection is typically conducted at mills that process
hardwoods; however, softwoods cut for export may also be surface
protected. Plants typically treat their lumber with surface protectants
only during humid months, depending on the region of the country in
which they operate. Wood that is kiln-dried is not normally surface-
protected. All green wood to be exported is protected. The most
popular surface protectant currently used by approximately 85% of all
major U.S. mills who treat lumber is a solution composed of 3-iodo-z-
propynyl butyl carbamate (IPBC), didecyl dimethyl ammonium
chloride (DDAC), and inert ingredients. The solution is diluted with
water to a ratio of 35-1 for spray box application and 100-1 for dip tank
applications.
Three major processes are used by sawmills to apply surface protectant
to wood: the dip process, the spray process, and the green chain
process. Typically the sawmill will use only one process to surface
protect; however, some plants use a combination of processes to protect
lumber at different locations throughout a mill. Dipping is a batch
process; green chain and spray operations are continuous processes.
The process used influences the amount of control a plant has over the
waste it generates during the surface protection process.
Dip operations offer the best opportunity to control drippage since an
owner or operator has the ability to keep the wood over the tank until
it stops dripping. Dipping operations can lead to uncontrolled drippage
when mills do not allow the treated loads to stop dripping before the
next load is dipped. Lumber is dipped in horizontal bundles, and as a
result, liquid is often trapped between pieces of wood. When forklifts
remove the lumber, large quantities of protectant can drip from the
wood onto the ground if the lumber is tipped.
Unlike dipping, the spray operation is a continuous process.
Individual pieces of lumber are fed end-to-end by chain, roller, or
conveyor belt through a spray box. The spray box is often equipped
with flexible brushes or curtains at both ends to isolate the formulation
spray and minimize drippage. A drip pan is usually incorporated into
the design of the spray box allowing formulation to return to the work
tank.
Green-chain systems represent another type of continuous operation.
The green-chain is so-named because chains drag fresh cut (or "green")
lumber through a tank of protectant formulation and back out again
for sorting and grading. A dip vat containing anti-stain formulation is
typically located at the head of the green chain and the wood falls into
this vat from the cutting operations. Some systems utilize wheels or
SIC Code 24
14
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
rollers just above the formulation surface to force the wood pieces into
the solution. As the wood is drawn from the vat and along the green
chain, excess formulation is released from the wood onto the return
drip pan. Green-chain operations are typically the least controllable
with respect to drippage.
Panel Products
This section describes two classes of panel products: (1) hardwood
veneer, softwood veneer, and plywood; and (2) reconstituted wood
products.
Hardwood Veneer and Softwood Veneer and Plywood
Veneer is a thin sheet of wood peeled or sliced from blocks of lumber
called flitches or logs. Veneer is glued together to form plywood.
Hardwood found in the Western and Southern U.S. is generally used
to manufacture hardwood plywood. Softwood logs from the
Northwest and Eastern U.S. are used to make softwood plywood.
Softwood plywood is primarily used for construction. Softwood
veneer and plywood is typically used for structural and industrial
applications and represents over 90 percent, by volume, of U.S.
production. Hardwood veneer and plywood is used typically for
decorative applications and for making interior paneling, components
for furniture and cabinets, and specialty products. There are several
other important differences between softwood plywood and hardwood
plywood: softwood plywood is generally made with relatively thick
faces (1/10" and thicker) and with exterior or intermediate glue (for
protected construction and industrial uses where moderate delays in
providing protection might be expected or conditions of high humidity
and water leakage may exist). Hardwood plywood is made with face
veneers generally 1/32" and thinner. Because of its nature and the use
of decorative thin face veneers, the glues used for hardwood plywood
tend to be colorless or light in color so as not to discolor the surfaces if
the adhesive bleeds into and through the thin faces. While most
hardwood plywood is all veneer, some is made with particleboard and
medium density fiberboard core.
The general processes for making softwood and hardwood plywood are
the same: log debarking, log steaming and or soaking, veneer cutting,
veneer drying, veneer preparation, glue application, pressing, panel
trimming, and panel sanding. These basic processes are illustrated in
Exhibit 7. Nevertheless, there are differences in details in these
softwood and hardwood plywood processes. Because of its greater
volume, this section primarily describes softwood veneer and plywood
manufacturing. However, it is noted where details of the
September 1995
15
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
manufacturing process are substantially different for hardwood
plywood.
Most softwood plywood plants also produce veneer. Most hardwood
plywood plants purchase components for making plywood from
outside sources. Logs received at the plant are debarked and cut into
lengths appropriate for the plant's processing equipment. Almost all
hardwood and many softwood blocks are heated prior to cutting or
peeling the veneer to soften the wood. The cut logs are heated by
steaming, soaking in hot water, spraying with hot water, or
combinations of these methods. The heating time required depends on
the diameter of the log, specific gravity, moisture content, and the
temperature needed to properly peel that particular species of wood.
The major methods for producing veneer are slicing and peeling. The
majority of veneer is produced by peeling (rotary cutting) on a veneer
lathe into sheets of uniform thickness. Slicing is used to produce
hardwood decorative veneers from a flitch generally in thicknesses of
1/24" and thinner, and is seldom used with softwood. In either case,
the wood is forced under a pressure bar that slightly compresses the
wood as it hits the cutting edge of a knife. On a rotary lathe, the block,
or log section, continuously rotates against the knife and the pressure
bar and peels a sheet of veneer from the heated block.
The veneer is peeled at a rate of 300 to 800 lineal feet/min. A series of
120-foot long trays is used in many softwood plywood plants to gently
handle these long sheets of wood as they are peeled from the chuck. In
softwood mills and some hardwood mills, high-speed clippers
automatically chop the veneer ribbons to usable widths at speeds of
1500 lineal feet/min. In hardwood mills, clipping may be done
manually to obtain the maximum amount of clear material from the
flitch.
After the veneer is peeled and clipped, it must be dried. Two types of
dryers are used in softwood veneer mills: roller resistant dryers, heated
by forced air; and platen dryers, heated by steam. In older roller dryers,
also still widely used for hardwood veneer, air is circulated through a
zone parallel to the veneer (see Exhibit 6). Most plants built in recent
years use jet dryers (also called impingement dryers) that direct a
current of air, at a velocity of 2,000 to 4,000 feet/min., through small
tubes on the surface of the veneer.
Veneer dryers may be heated indirectly with steam, generated by a
separate boiler, which is circulated through internal coils in contact
with dryer air. Dryers may also be heated directly by the combustion
gases of a gas- or wood-fired burner. The gas-fired burner is located
SIC Code 24
16
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
inside the dryer, whereas combustion gases from a wood-fired burner
are mixed with recirculating dryer air in a blend box outside the dryer
and then transported into the dryer. Veneer dryers tend to release
organic aerosols, gaseous organic compounds, and small amounts of
wood fiber into the atmosphere.
Exhibits
Veneer Dryer (Longitudinal)
CIRCULATING FANS
VENEER
INFEED
DIRECTION OF
AIRFLOW
(LONGITUDINAL)
Source: Basic Plywood Processing.
From the dryer, the sheets of veneer travel to a glue application station.
Narrow pieces of hardwood veneers are often joined with an adhesive
and/or string to maximize recovery. In the gluing process, also known
as layup, adhesive is applied to the individual sheets of veneer which
are later assembled into plywood. Various adhesive application
systems are used including hard rolls, sponge rolls, curtain coaters,
sprayers, and foam extruders. The most common application for
softwood plywood is an air or airless spray system, which generally
uses a fixed-head applicator capable of a 10-foot wide spray at a nozzle
pressure of 300 pounds per square inch (psi). Roller applications are
most common in the manufacture of hardwood plywood.
With spray systems, control of glue spreads is achieved by adjusting the
veneer conveyor speed, or by changing the size of the spray nozzle
orifice. Wastes generated in the layup process include adhesive waste
(typically overspray), and off-spec plywood.
September 1995
17
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
The phenol-formaldehyde (PF) typical in softwood plywood
manufacturing and urea-formaldehyde (UP) adhesions typically used
in hardwood plywood are made from resins synthesized in regional
plants and shipped to individual plywood mills. At the mills, the
resins are combined with extenders, fillers, catalysts, and caustic to
make a glue mixture. The addition of these ingredients modifies the
viscosity of the adhesive and allows it to be compatible with the glue
application method (curtain, roll, spray, foam); allows for better
adhesive distribution; increases the cure rate; and lowers cost.
Following the application of glue, the panels must be pressed. The
purpose of the press is to bring the veneers into close contact so that the
glue layer is very thin. At this point, resin is heated to the temperature
required for the glue to bond. Most plywood plants prepress the panels
in a cold press at lower pressure prior to final pressing in the hot press.
This allows the wet adhesive to "tack" the veneers together, permits
easier loading of the hot-press, and prevents shifting of the veneers
during loading. Pressing is usually performed in multiopening
presses, which can produce 20 to 40 4x8-foot panels in each two to
seven minute pressing cycle.
One of the goals of the pressing process is to use enough pressure to
bring the veneer surfaces together without overcompressing the wood.
Less pressure is required if the lathe has cut smooth veneer of a
uniform thickness.
After pressing, stationary circular saws trim up to one inch from each
side of the pressed plywood to produce square-edged sheets.
Approximately 20 percent of annual softwood plywood production is
then sanded. Over 90 percent of the hardwood plywood production is
sanded. As sheets move through enclosed automatic sanders,
pneumatic collectors above and below the plywood continuously
remove the sanderdust. Sawdust in trimming operations is also
removed by pneumatic collectors. The plywood trim and sawdust are
burned as fuel or sold to reconstituted panel plants. Exhibit 7 illustrates
the veneer and plywood manufacturing process.
SIC Code 24
18
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Exhibit 7
Flow Diagram of Veneer and Plywood Production
CO C
UJ I
to :
§ i
Q A '
g 1
§ 1
O
3
n
(
fe
JQUIDW
>
2
8
t
1
^
-*
11
o <
n
G
<
CO t
Q
UJ
2.
ffi
5
§
1
C
§
f
e
1
j
:
j
Q
O
O_
_J
I
5cr
sg
-a
icc
< LU
t- CO Q
JNUSABLE
ENEER AND
•RIMMINGS
^
of
1§
II
w ^
Q n.
f
Source: Estimating Chemical Releases from Presswood and Laminated Wood Products Manufacturing. U.S. EPA. Office
of Pesticides and Toxic Substances, March 1988.
Note: Many veneer and plywood plants are dry.
September 1995
19
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Reconstituted Wood Products
Reconstituted wood products, such as particleboard (PB), medium
density fiberboard (MDF), hardboard (HB), and oriented strand board
(OSB), is composed of furnish, or raw wood, that is combined with
resins and other additives and formed into a mat, which is then
pressed into a board. The manufacturing processes of these boards
differ, as do the raw materials used. For example, the furnish (raw
materials) used for particleboard consists of finely ground wood
particles of various sizes, while OSB is manufactured using specially-
prepared strands of wood. In general, the manufacturing processes
involve wood size reduction followed by drying (except for wet process
boards), adhesive application, pressing at elevated temperatures.
Because these products are based on use of all parts of the sawn log,
very little solid waste is generated. Instead, air emissions from dryers
and presses tend to be the principal environmental concern stemming
from the production of these products. Exhibit 8 compares the process
flows for some reconstituted wood product manufacturing processes.
Particleboard (PB)
Particleboard is a panel product made from wood particles of various
sizes that are bonded together with a synthetic resin such as urea-
formaldehyde (UP). The raw materials, or "furnish," that are used to
manufacture PB can be either green or dry wood residues. Green
residues include planer shavings from green lumber, and green
sawdust. Dry process residues include shavings from planing kiln-
dried lumber, sawdust, sanderdust and plywood trim. The wood
residues are ground into particles of varying sizes using flakers,
mechanical refiners, and hammermills. The material may be screened
prior to refining.
The furnish is dried to a low moisture content (two to six percent) to
allow for moisture that will be gained by the adding of resins and other
additives during "blending." Furnishes are generally no warmer than
100T when blended to avoid precuring and the drying out of the resin.
Most dryers currently in operation in PB and other reconstituted wood
panel manufacturing plants use large volumes of air to convey
material of varied size through one or more passes within the dryer.
Rotating drum dryers requiring one to three passes of the furnish are
most common. The use of triple-pass dryers predominates in the
United States (see Exhibit 9). Dryer temperatures may be as high as 1100
- 1200°F with a wet furnish. However, dry planer shavings require that
dryer temperatures be no higher than SOOT because the ignition point
SIC Code 24
20
September 1995
-------
Sector Notebook Project
Lumber and Wood Froducfs
Exhibit 8
Reconstituted Wood Panel Process Flow
WOOD REDUCTION
OSB
Logs are debarked
and cut into strands
BINDER APPLICATION
(forMDF)
Wood residues are
ground into fine particles
of varying sizes
MDF Hardboard
Dry
BINDER APPLICATION
(for OSB and PB)
Fiberboards
Wood residues are heated in a
steam cooker and mechanically
separated into fibers
Hardboard
Wet&
Wet/Dry
I
WET
FORMING
(Binder Applied)
Hardboard
Wet/Dry
source: (^naractenzation of Manufacturing Processes. Emissions, and Pollution Prevention - Options
for the Composite Wood Industry: Martin and Northeim, Research Triangle Institute Center for
Environmental Analysis, 1995.
September 1995
21
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
of dry wood is 446T. Dry material is the predominant furnish in
particleboard. Many dryers are directly heated by dry fuel suspension
burners. Others are heated by burning oil or natural gas.
Exhibit 9
Schematic of a Triple Pass Drum Dryer
MATERIAL
INLET
MATERIAL
EXIT
From
Burner
Source: Characterization of Manufacturing Processes. Emissions, ana Pollution prevention - upturn*
far the Composite Wood Industry: Martin and Nortlieim, Research Triangle Institute Center fin-
Environmental Analysis, 1995.
Direct-fired rotary drum dryers release emissions such as wood dust,
combustion products, fly ash, and organic compounds evaporated from
the extractable portion of the wood. Steam-heated and natural gas-
filled dryers will have no fly ash.
Air classifiers, which separate particles by surface area and weight, may
be used alone or in conjunction with screening equipment. Air
classifiers perform best if the feed is limited to particles with uniform
widths and lengths. The classifier can then efficiently separate particles
of different thicknesses due to the weight difference among particles of
approximately equal surface area. Undesired material is usually used
as fuel for the dryer burner. The screened particles are stored in dry
bins until they are conveyed to the blender. Air classifiers have limited
use in the industry. Screening systems are typically used to separate
fine from coarse material.
The furnish is then blended with a synthetic adhesives, wax, and other
additives distributed via spray nozzles, simple tubes, or atomizers.
Resin may be added as received (usually an aqueous solution); mixed
with water, wax emulsion, catalyst, or other additives. Waxes are
added to impart water repellency and dimensional stability to the
boards upon wetting.
Particles for PB are mixed with the additive in short retention time
blenders in through which the furnish passes in seconds. The blenders
consist of a small horizontal drum with high-speed, high shear
impellers and glue injection tubes. As the furnish enters the drum,
SIC Code 24
22
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
resin is injected, and the impellers hurl the furnish at high speeds to
mix it with the resin.
The furnish and resin mixture is then formed into mats using a dry
process. This procedure uses air or a mechanical system to distribute
the furnish onto a moving caul (tray), belt, or screen. Particleboard
mats are often formed of layers of different sized particles, with the
larger particles in the core, and the finer particles on the outside of the
board.
The mats are hot pressed to increase their density and to cure the resin.
Most plants use multiopening platen presses, which typically have 14
to 18 openings (see Exhibit 10). The last ten years has seen the
introduction of the continuous press. Though more popular in
Europe, the continuous press is currently being used in two PB plants
in the United States. Steam generated by a boiler that burns plant
residuals runs through a platen passageway to provide the heat in most
hot presses. Hot oil and hot water can also be used to heat the platens.
Primary finishing steps for all reconstituted wood panels include
cooling or hot stacking, grading, trimming/cutting, and sanding.
Cooling is important for UF-resin-cured boards since the resin degrades
at high temperatures after curing. Boards bonded using PF resins may
be hot-stacked to provide additional curing time. Secondary finishing
steps include filling, painting, laminating, and edge finishing. The vast
majority of reconstituted panel manufacturers do not apply secondary
finishes to their panels; panels are finished primarily by end-users such
as cabinet and furniture manufacturers. Panels are also finished by
laminators who then sell the finished panels to furniture and cabinet
manufacturers.
September 1995
23
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 10
Schematic of a Multi-Opening Board Press
SIMULTANEOUS
CLOSING
DEVICE
TOP PLATEN
OR CROWN
COLUMNS
PLATENS
OR PLATES
MOVING
TABLE OR
PLATEN
RAMS
Source: Characterization of Manufacturing Processes, Emissions, and Pollution Prevention - Options
for the Composite Wood Industry: Martin and Northeim, Research Triangle Institute Center for
Environmental Analysis, 1995.
SIC Code 24
24
September 1995
-------
Sectot Notebook. Project
Lumber and Wood Products
Medium Density Fiberboard (MDF)
Hardboard
The uses for this type of composite wood product are similar to those of
PB. The furnish used to manufacture MDF consists of the same type of
green or dry wood residues used to manufacture PB and hardboard.
Fibers and fiber bundels are generated by first steam-heating the wood,
then passing it through a refiner. During this step the wood changes
both chemically and physically; becoming less susceptible to the
influences of moisture and less brittle as the lignin in the wood softens.
This semi-plastic wood is then "rubbed" apart into fibers and fiber
bundles in a refiner instead of being mechanically "broken" apart as in
the PB manufacturing process.
The furnish is dried to a very low moisture content to allow for
moisture to be gained by the addition of resins and other additives.
Most MDF furnish is dried in tube dryers.
The blending process for MDF differs from that of PB in that it typically
occurs before drying. After refining, the fibers are discharged through a
valve known as the blowvalve into the blowline, a larger continuous
chamber where the UF resins are mixed with the wood fiber. In the
blowline, the fibers are sprayed with a resin which is injected from a
line located either immediately after the blowvalve or anywhere along
the blowline. Material is dried to an acceptable moisture content in a
flash tube dryer at low temperatures after the blowline. If the blending
is done mechanically, as in PB, it is done after the flash tube dryer.
MDF is formed using a dry process which uses air to distribute the
furnish in a random orientation onto a moving caul (tray), belt, or
screen. The mats are then pressed using a multi-opening platen press
or a continuous press is currently used in three MDF plants in the
United States. The boards are then cooled and finished like other
reconstituted wood panels.
Hardboard is a higher-density version of MDF. It is typically used for
siding, furniture drawer bottoms, dust stops, sliding doors, and cabinet
doors and tops. There are three types of hardboard: wet, wet/dry, and
dry process hardboard, each classified by their manufacturing processes.
The furnish used to manufacture hardboard consists of the same green
or dry process wood residues used to manufacture PB and MDF. The
cooked semi-plastic furnish is "rubbed" apart into fiber bundles as in
the MDF process. The fibers are all the same size, therefore, they need
no screening.
September 1995
25
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
In the manufacture of wet, and wet/dry process hardboard, the furnish
is not dried because the forming process uses water. Wet and wet/dry
process hardboard mats are formed using a wet process in which fibers
are mixed with water and Phenol Formaldehyde adhesive and then
metered onto a wire screen. Water is drained away with the aid of
suction applied to the underside of the wire. The fiber mat, along with
the supporting wire, is moved to a prepress where excess water is
squeezed out. Wet/dry process hardboard is dried in an oven before
being hot pressed.
In the manufacture of dry process hardboard, the furnish is dried using
dryers typical of the reconstituted wood panel industry. As with MDF,
the hardboard fibers are discharged through a blowvalve into a
blowline after refining. Dry process hardboard mats are formed using a
process similar to that of MDF and PB in which air is used to distribute
the Tarnish in a random orientation onto a moving caul (tray), belt, or
screen. All reconstituted wood panels are hot pressed to increase their
density and to cure the resin.
Oriented Strandboard
The furnish used to manufacture OSB is specially flaked from
roundwood. Logs entering OSB plants may be either tree length or cut
to 100 inch lengths by a slasher saw. The logs are then debarked and
sent to a strander which slices them into strands approximately 0.028
inch thick. The strands are then conveyed to a storage bin to await
processing through the dryers. (Note: Some older mills cut the logs
into 33 inch blocks before sending them to the strander.)
The strands are dried to a low moisture content to allow for moisture
gained by adding resins and other additives. The strands are then
blended with additives in long retention time blenders in which the
furnish passes through in several minutes. The blenders are very large
rotating drums (several feet in diameter and many feet in length) that
are tilted on their axes. As the strands are fed into the drums, they are
sprayed with either PF or MDI (Methylenediphenyl diisocyanate) resin
and either liquid or emulsified paraffin wax. The tumbling action of
the strands through the drums allows the strands to mix thoroughly
with the resin and wax.
OSB is formed by a dry process, which uses air to distribute the furnish.
OSB is produced by deliberate mechanical lining-up of the strands. In
the mechanical orientation processes, mats are produced by dropping
long slender flakes between parallel plates or disks onto a moving caul
(tray), belt, or screen. The boards are then hot pressed and finished.
SIC Code 24
26
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
strand lumber, made from long strands of veneer, is extruded with PF
resin into various cross sections and widths. Parallel laminated
veneer, or laminated veneer lumber (LVL), is constructed of veneers
that are bonded together with phenol-formaldehyde (PF) adhesive
resin to form a laminate. The veneers are layered with the wood grain
along the long axis of the beam. Laminated veneer lumber is
manufactured to typical lumber sizes (2 x 4, 2 x 6, etc.). The length of
the beams that can be manufactured is varied using end joints or finger
joints. Another application of LVL is in the construction of wood "I"
joists (a small beam that resembles the letter "I"). LVL is used to
construct the top and bottom (flanges) of the joist and OSB or plywood
is used to construct the center (web).
Glulam beams are also emerging as a substitute for lumber. Glulam is
short for glued-laminated structural timber - large beams fabricated by
bonding layers of specially-selected lumber with Resorcinol or
Resorcinol/PF adhesives and timber. End and edge jointing permit
production of longer and wider structural wood members than are
available naturally. Glulam timbers are used with structural wood
panels for many types of heavy timber construction.
Most of the engineered lumber products are used as substitutes for
structural softwood lumber of large sizes and in applications where
uniform strength is essential. I-beams, however, are finding wide
application, with extensive use as floor joists and beams for various
structures. There are several advantages of composite lumber when
compared with sawn softwood lumber. First, these products allow
production of large sizes of lumber from small, low-grade logs.
Normally, relatively large and high-grade sawlogs are needed for
production of lumber of this size. Second, composite lumber compares
advantageously to solid sawn lumber in terms of both uniformity of
quality and straightness. While the quality of lumber is determined to
a great extent by the raw material, the quality of the reconstituted
product is dependent upon the manufacturing process. It is likely,
however, that use of composite lumber will increase in the future.
Wood Preserving
Wood is treated with preservatives to protect it from mechanical,
physical, and chemical influences. Preserved wood is used primarily in
the construction, railroad, and utilities industries to prevent rotting
when wood is exposed to damp soil, standing water, or rain, and as
protection against termites and marine borers. The most common
preservatives include water-borne inorganics like chromated copper
arsenate (CCA) and ammoniacal copper zinc arsenate (ACZA), and oil-
borne organics like pentachlorophenol (PCP) and creosote. Generally,
September 1995
27
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
protection against termites and marine borers. The most common
preservatives include water-borne inorganics like chromated copper
arsenate (CCA) and ammoniacal copper zinc arsenate (ACZA), and oil-
borne organics like pentachlorophenol (PCP) and creosote. Generally,
water-borne inorganic solutions constitute approximately 78 percent of
all preservatives used, while oil-borne creosote and PCP comprise 15
percent and 6 percent, respectively.
Creosote, PCP, and inorganic wood preservatives are all applied using
similar processes. More than 90 percent of the wood preservation in
the U.S. is performed using pressure treatment processes. Exhibit 10
illustrates a two-cylinder pressure treatment process for CCA. A
limited quantity of wood is preserved using non-pressure treatment
processes in which the preservative is allowed to diffuse into the wood.
This process is used with some oil-borne preservatives, but not with
waterborne inorganics.
The penetration required to adequately preserve wood can be achieved
only if the wood has been conditioned properly; that is, if the moisture
content of the freshly-cut wood is reduced to a point where the
preservative can penetrate and be retained by the wood. Wood is
usually conditioned in the open air or conditioned in the cylinder
(retort) in which the pressure treatment is performed. The sawn
lumber is sometimes incised to increase preservative penetration.
Open air drying is typically used to prepare large stock for treatment
with oil-borne preservatives. Other methods for conditioning wood
prior to treatment with oil-borne preservatives include steaming,
heating, and vapor drying. Kiln drying is used primarily for water-
borne treatment. Conditioning is a major source of wastewater in the
wood preserving industry.
After the moisture content of the wood has been reduced, the wood is
preserved using either non-pressure or pressure methods. Non-
pressure processes include brushing, spraying, dipping, soaking, and
thermal processes. These processes involve the repeated use of
preservative in a treatment tank with fresh preservative solution
added to replace consumptive loss. The continual reuse of
preservative leads to the accumulation of wood chips, sand, stones, and
other debris contaminated with various hazardous constituents in the
bottom of the treating tanks. This contaminated debris is a major
source of process waste for non-pressure processes.
SIC Code 24
28
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Exhibit 11
Example Flow Diagram For a Two-Cylinder CCA Pressure-Treating Facility
In-Process r-
Preservative
Drip Recovery
. CCA
^Treated
Wood
- Solid Waste Managed in Containers (including Sawdust, Dirt, and Road Grime) for Subsequent Off-Site Disposal
- Filter
source: 1 Me ILL, bection Jl6 Release Reporting Guidance: Office of Pesticides and Toxic Substances; March 1983.
There are two basic types of pressure treatment processes, distinguished
by the sequence in which vacuum and pressure are applied. These are
"empty-cell" and "full-cell" or "modified full cell" processes. The
terms "empty" and "full" are measures of the level of preservative
retained by the wood cells.
"Empty-cell" processes obtain relatively deep penetration with limited
absorption of preservative. In the Reuping empty-cell process, air
pressure is applied to the wood as preservative is pumped into the
treating cylinder. Once the desired level of retention has been
achieved, the unused preservative is drained off and the excess
preservative is vacuum pumped away from the wood. The process is
the same in the Lowry empty-cell process, except no initial pressure is
applied. In both processes, air compressed in the wood drives out part
of the preservative absorbed during the pressure period when pressure
is released.
September 1995
29
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
The second method, know as the "full-cell" (Bethel) process, results in.
higher retention of preservative but limited penetration compared to
the empty-cell process. The full-cell or modified full cell procedures
are used with both oil- and water-borne preservatives. A vacuum is
created in the treating cylinder and preservative is pumped in without
breaking the vacuum. Once full, hydrostatic or pneumatic pressure is
applied until the wood will retain no more preservative. A final
vacuum may then be applied to remove excess preservative, which is
returned to the work tank for reuse. The treated wood is removed
from the cylinder and placed on a drip pad where it remains until
dripping has ceased (see Exhibit 12). Preservative solution, washdown
water, and rainwater are collected on the drip pad and maintained, in.
the process. At waterborne plants, these materials are transferred to a
dilution water tank where they are blended with additional concentrate
to make fresh treating solution. At oil-borne plants, these materials are
processed to recover preservative and usable process water. Excess
waste water is treated either on-site in a wastewater treatment unit or
off-site at a publicly owned treatment works.
Exhibit 12
Drip Pad with Liner
Rail System for Wood Treating
Cylinder Trams
Granular Fill
Sand
Source: U.S. EPA.
SIC Code 24
30
September 1995
-------
Sector Notebook. Project
Lumber and Wood Products
III.B. Raw Material Inputs and Pollution Outputs
Exhibit 13 provides an overview of the material inputs and pollution
outputs for different processes in the lumber and wood products
industry.
Logging
With the exception of concerns for species and ecosystem preservation,
harvesting practices have minimal environmental impacts.
Harvesting practices often cause discharges of materials into
surrounding waters, threatening water quality standards. The Federal
Water Protection Control Act regulates these discharges. In addition,
road construction for access to timber areas is of concern, due to
impacts on surrounding ecosystems.
September 1995
31
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 13
Process Materials Inputs and Pollution Outputs
Process
Logging
Sawing
Surface
Protection
Plywood and
Veneer
Reconstituted
Wood Products
Wood
Preserving
Material Input
Trees, diesel, gasoline
Wood logs, diesel,
gasoline
Wood, 3-Iodo-2-Propynyl
Butyl Carbamate (IPBC),
Didecyl Dimethyl
Ammonium Chloride
(DDAC)
Veneer, phenol-
formaldehyde resins,
urea-formaldehyde resins,
melamine-formaldehyde
resins, sodium hydroxide,
ammonium sulfate, acids,
ammonia
Wood particles, strands,
fiber, same resins as
plywood and veneer,
methylenediphenyl
diisocyanate resins
Wood, pentachlorophenol,
creosote, borates,
ammonium compounds,
inorganic formulations of
chromium, copper, and
arsenic, carrier oils
Air Emissions
PM-10, VOCs, CO,
NOx
PM-10, VOCs, CO,
NOx
IPBC, DDAC, ethyl
alcohol, petroleum
naphtha
PM-10, VOCs, CO,
CO2, NOx,
formaldehyde,
phenol, wood dust,
condensable
hydrocarbons,
terpenes, methanol,
acetic acid, ethanol,
furfural
PM-10, VOCs, CO,
C02, NOx,
formaldehyde,
phenol, wood dust,
condensable
hydrocarbons,
terpenes, methanol,
acetic acid, ethanol,
furfural
Pentachlorophenol,
polycyclic organics,
creosote, ammonia,
boiler emissions, air-
borne arsenics, VOCs
Process Waste
Not applicable
Not applicable
Dripped
formulation mixed
with rainwater and
facility washdown
water
Not applicable
Not applicable
Dripped
formulation mixed
with rainwater and
facility washdown
water, kiln
condensate, contact
cooling water
Other Waste
Waste wood
particles
Waste wood
particles
Sawdust,
wood chips,
sand, dirt,
stones, tar,
emulsified or
polymerized
oils
Waste wood
particles,
adhesive
residues
Waste wood
particles,
adhesive
residues
Bottom
sediment
sludges,
process
residuals
Sazvn Lumber
Most of the residual wood from sawn lumber production is reused as
mulch, pulp, and furnish for some types of reconstituted wood panels;
some is burned to produce steam or electricity. Studies cited by the
Western Wood Products Association indicate that approximately 70
percent of a sawn log is utilized for lumber and other parts are used for
co-products. Some of the small residuals are gathered with pneumatic
SIC Code 24
32
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
systems for combination with larger amounts destined for use in other
products. While there is virtually no waste from the manufacturing
process because all parts of the log are used for one product or another,
wood residuals are high in organic matter and can threaten aquifers if
improperly handled.
A major emission of concern from wood boilers is particulate matter
(PM), although other pollutants, particularly CO and organic
compounds, may be emitted in significant quantities under poor
operating conditions. Boilers that burn wood waste produce: fly ash,
carbon monoxide, and volatile organic compounds (VOCs). New
boilers must meet new source performance standards (NSPS) for air
pollutants. In addition, mills are potential sources of toxic manganese
air emissions.
Two types of primary waste streams are typically generated during the
surface protection phase of sawn lumber production operations:
process residuals and drippage. Secondary waste streams include spent
formulations and wastewaters.
Typical process residuals from surface protection are tank sludges that
accumulate in the dip tank and/or mix tank as a result of continuous
reuse of the protectant. Some plants use spray systems that generate a
sludge when recovered formulation is filtered. Periodically, the
accumulated sludge must be removed, and is typically placed on
sawdust or wood chip piles on-site. The ultimate destination of the
sludge is dependent upon the management of the sawdust piles. Plants
have reported-burning sawdust on-site or shipping it off-site for use as
boiler feed for energy recovery. Depending upon the particle size, some
wood chips may be shipped to a pulp or paper mill.
Some plants generate little or no tank sludge as a result of certain
process variations. Dip tank operations sometimes utilize an internal
circulation system to enhance mixing and promote penetration into
the packed bundles. The agitation does not allow any particulates to
settle, and when the bundles are removed, some of the suspended
solids are also removed. Green-chain operations sometimes use a
system of rollers that are partially submerged into the dip tank. These
rollers force the pieces of lumber under the surface of the formulation
to ensure thorough coverage of the exposed surfaces. Forcing the
lumber deeper into the tank physically drags the lumber through any
sludge that has settled in the tank and this sludge leaves the tank with
the treated lumber.
Another wastestream results from the excess formulation drippage
from freshly surface protected lumber. In the absence of a drip pad,
September 1995
33
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
excess drippage can fall on the ground when the wood is transported
from the dip tank or green chain to stacking and packaging areas. Spray
operations tend to result in less excess formulation on the wood than
either "the dipping or green-chain operations. Some plants utilize
simple recovery systems to minimize the loss of formulation. For
example, pack dip operations hold the wood over the dip tank at an
angle to collect excess formulation prior to transfer to storage. Green
chain and spray operations may utilize a collection pan under the
conveyor to collect formulation as the freshly treated lumber runs
along the green chain.
Panel Products
Dryers
In mills where chips or other furnish is generated on-site, operations
such as debarking, sanding, chipping, grinding, and fiber separation
generate PM emissions in the form of sawdust and wood particulate
matter. The following discussion of pollution outputs from panel
production is not divided along product lines. Instead, due to
similarities in manufacturing process, this section describes pollution
outputs during the drying and pressing stages, where most emissions
occur.
Organic aerosols and gaseous organic compounds, along with a small
amount of wood fiber are found in the emissions from veneer
impingement dryers. A mixture of organic compounds is driven from
the green wood veneer as its water content is converted to steam in the
drying process. Aerosols begin to form as the gaseous emissions are
cooled below 302°F. These aerosols form visible emissions called blue
haze.
Emissions from the rotating drum wood chip dryers used in
reconstituted wood panel plants are composed of wood dust,
condensable hydrocarbons, fly ash, organic compounds evaporated
from the extractable portion of the wood, and may include products of
combustion such as CO, CO2, and NOX if direct-fired units are used.
The organic portion of industry emissions includes terpenes, resin and
fatty acids, and combustion and pyrolysis products such as methanol,
acetic acid, ethanol, formaldehyde, and furfural. The condensable
hydrocarbons and a portion of the VOCs leave the dryer stack as vapor
but condense at normal atmospheric temperatures to form liquid
particles that create the blue haze. Both the VOCs and the liquid
organic mist are combustion products and compounds evaporated
from the wood. Quantities emitted are dependent on wood species,
dryer temperature, and fuel used.
SIC Code 24
34
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Presses
One significant cause of blue haze is overloading a dryer by attempting
to remove too much moisture within a given time. Overloading
results in the introduction of green material to a high-temperature
flame or gas stream causing a thermal shock that results in a rapid and
excessive volatilizing of hydrocarbons that condense upon release to
ambient air, causing the characteristic blue haze.
Another factor affecting the composition of the effluent from rotary
drum dryers is inlet dryer temperatures. A study conducted in 1986 by
The National Council of the Paper Industry for Air and Stream
Improvement (NCASI) with data from five different mills using rotary
drum dryers concluded that at inlet gas temperatures greater than
600°F, the emission rate of the total condensable portion of total
gaseous nonmethane organics (TGNMO) increased as a function of
temperature. The report concluded that the concentration of
formaldehyde in the dryer exhaust was also directly related to dryer
inlet temperature.
The type of wood species fettmed also affects the composition of the
effluent from rotary drum dryers. A second NCASI study concluded
that high TGNMO emission rates from the dryers occurred when the
wood species processed had high turpentine contents, such as Southern
Pine. In a separate study on formaldehyde emissions, NCASI showed
that dryers processing hardwood or a mixture of hardwood and
softwood species had a moderate to dramatic increase in formaldehyde
emissions at dryer inlet gas temperatures greater than 800 °F, but dryers
processing only softwood species had only a slight increase in
formaldehyde emissions with increasing temperatures.
Emissions from board presses are dependent upon the type of resin
used to bind the wood furnish together. Emissions from hot presses
consist primarily of condensable organics. When the press opens,
vapors that may include resin ingredients such as formaldehyde,
phenol, MDI, and other organic compounds are released to the
atmosphere through vents in the roof above the press. Formaldehyde
emitted through press vents during pressing and board cooling
operations is dependent upon the amount of excess formaldehyde in
the resin as well as press temperature and cycle time.
Mole ratios are used to measure the number of moles of one
compound to another in an adhesive. For example, the F:U
(formaldehyde to urea) mole ratio measures the number of moles of
formaldehyde to the number of moles of urea in the principal adhesive
September 1995
35
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
used for PB and MDR The nature of the product and the process
dictates the mole ratio of resin used. The ratio directly impacts the
ultimate strength the resin will produce in the board, i.e., certain
products require higher mole ratio resins to attain an adequate level of
bond strength. The higher the mole ratio, the higher the board
emissions of formaldehyde. Thus lowering the F:U mole ratio is one
way of lowering press and board emissions of formaldehyde. However,
mole ratio is only one of several variables that can effect formaldehyde
emissions. Other variables include application rates, process rates, and
the nature of the specific resin formations.
Higher press temperatures generally result in higher formaldehyde
emissions. In an NCASI study, emissions of formaldehyde and phenol
from PF resins (used mainly for OSB) and structural plywood were not
found to be related to any operating procedures, but were affected by
different resin compositions. The types of resins used can effect the
amount of emissions. There was little information on emissions from
the curing of MDI resins (used for OSB along with PF resins).
Wood Preserving
The chemicals used in the wood preserving process and the drip pads
used to collect preservative drippage after treatment of wood have been
the subject of considerable regulatory action. EPA has issued final
regulations regarding wood preserving wastewater, process residuals,
preservative drippage, and spent preservatives from wood preserving
processes at facilities that use chlorophenolic formulations, creosote
formulations, and inorganic preservatives containing arsenic or
chromium.
There are six EPA-classified hazardous wastes from wood preserving
operations. These are: U051, discarded unused creosote, F027,
discarded unused pentachlorophenol-formulation; K001, bottom
sediment sludge from the treatment of wastewaters from wood
preserving processes that use creosote or PCP; F032, wastewaters,
process residuals, preservative drippage, and spent formulations from
wood preserving processes generated at plants that currently use or
have previously used chlorophenolic formulations; F034, wastewaters,
process residuals, preservative drippage, and spent formulations from
wood preserving processes generated at plants that use creosote
formulations; and F035, wastewaters, process residuals, preservative
drippage, and spent formulations from wood preserving processes
generated at plants that use inorganic preservatives containing arsenic
or chromium.
SIC Code 24
36
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Drips and spills during the oilborne preservative process may occur
during chemical delivery, chemical storage and mixing, freshly-treated
wood storage on bare ground (if RCRA guidelines are not followed),
and dry-treated wood storage on ground. Aerosols and vapors may be
released to ambient air during chemical storage and mixing, solution
storage, and during pressure treatment (once the cylinder is opened).
Sludges result if filters are used prior to solution reuse from
wastewater treatment, and from the collection sumps at the facility.
During the inorganic treatment process, additional vapors such as
arsenic, may be released to ambient air during the pressure treating
process, such as from the process tank or work vent during the initial
vacuum stage, the flooding via vacuum, pressure relief and blow back,
and the final vacuum. Aerosols and vapor may also be released from
the cylinder door area during pressure treating and door opening.
Wood preserving facilities generate wastewater during the
conditioning of the wood prior to its treatment and as a result of the
condensation removed from the treatment cylinder. Rainwater, spills
collected from the area around the treatment cylinder, and drip pad
wash down water also contribute to wastewater volume. Typical air
emissions sources are volatilization of organic chemicals during
wastewater evaporation, vapors released from the treating cylinder
during unloading and charging operations, and emissions from the
vacuum vent during the treating cycle.
After both pressure and non-pressure treatment, some unabsorbed
preservative formulation adheres to the treated wood surface.
Eventually, this liquid drips from the wood or is washed off by
precipitation. If the wood has been pressure treated, excess
preservative will also exude slowly from the wood as it gradually
returns to atmospheric pressure. This is known as "kickback."
Current regulations specify that all wood must be drip-free prior to
transfer from a drip pad to a storage yard. Also, storage-yard drippage
resulting from "kickback" must be cleaned up within 72 hours of the
occurrence. Preservative formulation may continue to exude from
pressure and non-pressure treated wood for long periods, even after
the wood is shipped off-site and installed for its intended end use. (See
Exhibit 11 for schematic of wood preserving process and waste
generation)
September 1995
-37
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
m.C. Management of Chemicals in Wastestream
The Pollution Prevention Act of 1990 (EPA) requires facilities to report
information about the management of TRI chemicals in waste and
efforts made to eliminate or reduce those quantities. These data have
been collected annually in Section 8 of the TRI reporting Form R.
beginning with the 1991 reporting year. The data summarized below
cover the years 1992-1995 and is meant to provide a basic
understanding of the quantities of waste handled by the industry, the
methods typically used to manage this waste, and recent trends in these
methods. TRI waste management data can be used to assess trends in
source reduction within individual industries and facilities, and for
specific TRI chemicals. This information could then be used as a tool
in identifying opportunities for pollution prevention and compliance
assistance activities.
While the quantities reported for 1992 and 1993 are estimates of
quantities already managed, the quantities reported for 1994 and 1995
are projections only. The EPA requires these projections to encourage
facilities to consider future waste generation and source reduction of
those quantities as well as movement up the waste management
hierarchy. Future-year estimates are not commitments that facilities
reporting under TRI are required to meet.
Exhibit 14 shows that the lumber and wood products industry managed
about 69 million pounds of production-related waste (total quantity of
TRI chemicals in the waste from routine production operations) in
1993 (column B). Column C reveals that of this production-related
waste, 17 percent was either transferred off-site or released to the
environment. Column C is calculated by dividing the total TRI
transfers and releases by the total quantity of production-related waste.
In other words, about 84 percent of the industry's TRI wastes were
managed on-site through recycling, energy recovery, or treatment as
shown in columns D, E and F, respectively. The majority of waste that
is released or transferred off-site can be divided into portions that are
recycled off-site, recovered for energy off-site, or treated off-site as
shown in columns G, H, and I, respectively. The remaining portion of
the production-related wastes (13.2 percent), shown in column J, is
either released to the environment through direct discharges to air,
land, water, and underground injection, or it is disposed off-site.
From the yearly data presented below it is apparent that the portion of
TRI wastes reported as recycled on-site has increased and the portions
treated or managed through energy recovery on-site have decreased
between 1992 and 1995 (projected).
SIC Code 24
38
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Exhibit 14
Source Reduction and Recycling Activity for SIC 24
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
(106lbs.)*
33
69
66
63
C
% Reported
as Released
and
Transferred
45%
17%
—
—
D
E
F
On-Site
%
Recycled
55.17%
78.30%
79.59%
79.15%
% Energy
Recovery
0.10%
0.05%
0.07%
0.03%
%
Treated
11.02%
5.90%
5.32%
5.63%
G
H
I
Off-Site
%
Recycled
0.06%
0.07%
0.08%
0.09%
% Energy
Recovery
-1.84%
1.36%
0.86%
0.74%
%
Treated
2.12%
1.09%
0.59%
0.62%
J
Remaining
Releases
and
Disposal
29.69%
13.23%
13.50%
13.72%
September 1995
39
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the
pollutant releases that are reported by this industry. The best source of
comparative pollutant release information is the Toxic Release
Inventory System (TRI). Pursuant to the Emergency Planning and
Community Right-to-Know Act, TRI includes self-reported facility
release and transfer data for over 600 toxic chemicals. Facilities within
SIC Codes 20-39 (manufacturing industries) that have more than 10
employees, and that are above weight-based reporting thresholds are
required to report TRI on-site releases and off-site transfers. The
information presented within the sector notebooks is derived from the
most recently available (1993) TRI reporting year (which then included
316 chemicals), and focuses primarily on the on-site releases reported
by each sector. Because TRI requires consistent reporting regardless of
sector, it is an excellent tool for drawing comparisons across industries.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general,
toxic chemical releases have been declining. In fact, according to the
1993 Toxic Release Inventory Data Book, reported releases dropped by
42.7% between 1988 and 1993. Although on-site releases have
decreased, the total amount of reported toxic waste has not declined
because the amount of toxic chemicals transferred off-site has
increased. Transfers have increased from 3.7 billion pounds in 1991 to
4.7 billion pounds in 1993. Better management practices have led to
increases in off-site transfers of toxic chemicals for recycling. More
detailed information can be obtained from EPA's annual Toxics
Release Inventory Public Data Release book (which is available
through the EPCRA Hotline at 1-800-535-0202), or directly from the
Toxic Release Inventory System database (for user support call 202-260-
1531).
Wherever possible, the sector notebooks present TRI data as the
primary indicator of chemical release within each industrial category.
TRI data provide the type, amount, and media receptor of each
chemical released or transferred. When other sources of pollutant
release data have been obtained, these data have been included to
augment the TRI information.
TRI Data Limitations
The reader should keep in mind the following limitations regarding
TRI data. Within some sectors, the majority of facilities are not subject
to TRI reporting because they are not considered manufacturing
industries, or because they are below TRI reporting thresholds.
SIC Code 24
40
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Examples are the mining, dry cleaning, printing, and transportation
equipment cleaning sectors. For these sectors, release information
from other sources has been included.
The reader should also be aware that TRI "pounds released" data
presented within the notebooks is not equivalent to a "risk" ranking
for each industry. Weighting each pound of release equally does not
factor in the relative toxicity of each chemical that is released. The
Agency is in the process of developing an approach to assign
toxicological weightings to each chemical released so that one can
differentiate between pollutants with significant differences in toxicity.
As a preliminary indicator of the environmental impact of the
industry's most commonly released chemicals, the notebook briefly
summarizes the toxicological properties of the top five chemicals (by
weight) reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code - the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal
economic statistics. The SIC codes facilitate comparisons between
facility and industry data.
TRI Facilities — are manufacturing facilities that have 10 or more full-
time employees and are above established chemical throughput
thresholds. Manufacturing facilities are defined as facilities in
Standard Industrial Classification primary codes 20-39. Facilities must
submit estimates for all chemicals that are on the EPA's defined list
and are above throughput thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions
developed by EPA's Toxic Release Inventory Program. The categories
below represent the possible pollutant destinations that can be
reported.
RELEASES -- are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to bodies
of water, releases at the facility to land, as well as contained disposal
into underground injection wells.
Releases to Air (Point and Fugitive Air Emissions) — Include all air
emissions from industry activity. Point emissions occur through
September 1995
41
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
confined air streams as found in stacks, ducts, or pipes. Fugitive
emissions include losses from equipment leaks, or evaporative losses
from impoundments, spills, or leaks.
Releases to Water (Surface Water Discharges) - encompass any releases
going directly to streams, rivers, lakes, oceans, or other bodies of water.
Any estimates for stormwater runoff and non-point losses must also be
included.
Releases to Land — includes disposal of waste to on-site landfills, waste
that is land treated or incorporated into soil, surface impoundments,
spills, leaks, or waste piles. These activities must occur within the
facility's boundaries for inclusion in this category.
Underground Injection — is a contained release of a fluid into a
subsurface well for the purpose of waste disposal.
TRANSFERS — is a transfer of toxic chemicals in wastes to a facility that
is geographically or physically separate from the facility reporting
under TRI. The quantities reported represent a movement of the
chemical away from the reporting facility. Except for off-site transfers
for disposal, these quantities do not necessarily represent entry of the
chemical into the environment.
Transfers to POTWs — are wastewaters transferred through pipes or
sewers to a publicly owned treatments works (POTW). Treatment and
chemical removal depend on the chemical's nature and treatment
methods used. Chemicals not treated or destroyed by the POTW are
generally released to surface waters or landfilled within the sludge.
Transfers to Recycling — are sent off-site for the purposes of
regenerating or recovering still valuable materials. Once these
chemicals have been recycled, they may be returned to the originating
facility or sold commercially.
Transfers to Energy Recovery — are wastes combusted off-site in
industrial furnaces for energy recovery. Treatment of a chemical by
incineration is not considered to be energy recovery.
Transfers to Treatment — are wastes moved off-site for either
neutralization, incineration, biological destruction, or physical
separation. In some cases, the chemicals are not destroyed but prepared
for further waste management.
Transfers to Disposal — are wastes taken to another facility for disposal
generally as a release to land or as an injection underground.
SIC Code 24
42
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
IV.A. EPA Toxic Release Inventory for the Lumber and Wood Products Industry
TRI Release amounts listed below are not associated with non-
compliance with environmental laws. These facilities appear based on
self-reported data submitted to the Toxic Release Inventory program.
The TRI database contains a detailed compilation of self-reported,
facility-specific chemical releases. The top reporting facilities for this
sector are listed below. Facilities that have reported only the SIC codes
covered under this notebook appear in Exhibit 15. Exhibit 16 contains
additional facilities that have reported the SIC code covered within this
report, and one or more SIC codes that are not within the scope of this
notebook. Therefore, Exhibit 16 includes facilities that conduct
multiple operations — some that are under the scope of this notebook,
and some that are not. Operations in Exhibit 16 include: 2621 - paper
mills, 2611 - pulp mills, 2631 - paper mills, and 2812 - industrial
inorganic chemicals. Currently, the facility-level data do not allow
pollutant releases to be broken apart by industrial process.
Exhibits 17-19 illustrate the TRI releases and transfers for the lumber
and wood products industry (SIC 24). For the industry as a whole,
VOCs (such as formaldehyde, xylene, toluene, and methanol) comprise
the largest number of TRI releases. A large amount of VOC releases,
both fugitive and point source emissions, result in part from the
extensive use of glues and resins in this industry. VOCs are primarily
released during the drying and pressing phases of most wood panel
product manufacturing processes. VOC emissions are also associated
with solvents used to coat cabinets, decorative panels, and toys.
September 1995
43
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 15
Top 10 TRI Releasing Lumber and Wood Product Facilities (SIC 24 only)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
638,622
386,994
383,100
341,200
261,000
241,010
234,697
199,000
197,800
179,000
Facility Name
Merillat Ind. Inc.
Component Concepts Inc.
Child Craft Inc. Co. Inc.
Afco Ind. Inc.
Decolam Inc.
Abt Co. Inc.
Weyerhaeuser Particleboard Mill
J. H. Baxter & Co.
Georgia-Pacific Corp. Monticello
Panelboard
Northwood Panelboard Co.
City
Mount Jackson
Thomasville
Salem
Holland
Orangeburg
Roaring River
Adel
Weed
Monticello
Solway
State
VA
NC
IN
MI
SC
NC
GA
CA
GA
MN
Source: U.S. EPA, Toxics Release Inventory Ua.ta.oase,
Exhibit 16
Top 10 TRI Releasing Lumber and Wood Product Facilities
SIC Codes
2621, 2611,
2812,2421
2621, 2421,
2436
2611, 2621,
2631,2421
2631, 2436,
2499
2426
2493
2435
2493
2439
2493
Total TRI
Releases in
Pounds
1,273,125
1,187,356
1,059,615
768,369
638,622
386,994
383,100
341,200
261,000
241,010
Facility Name
Weyerhaeuser Co.
MacMillian Bloedel Inc.
Potlatch Corp. Pulp &
Paperboard Group
Weyerhaeuser Co.
Containerboard Packaging
Div.
Merillat Ind. Inc.
Component Concepts Inc.
Child Craft Inc. Co. Inc.
AFCO Ind. Inc.
Decolam, Inc.
Abt Co. Inc.
City
Longview
Pine Hill
Lewiston
Springfield
Mount Jackson
Thomasville
Salem
Holland
Orangeburg
Roaring River
State
WA
AL
ID
OR
VA
NC
IN
NH
SC
NC
Source: U.S. EPA, Toxics Release Inventory Database,
Mote: Being included on these lists does not mean that the release is associated with non-compliance
with environmental laws.
SIC Code 24
44
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Exhibit 17
TRI Reporting Lumber and Wood Product Facilities (SIC 24) by
State
State
AL
AR
AZ
CA
CO
CT
PL
GA
HI
ID
IL
IN
KY
LA
MA
MD
ME
MI
MN
MO
MS
MX
NC
Number of
Facilities
43
18
2
19
3
1
19
35
4
3
9
11
8
17
3
6
4
13
12
6
28
2
31
State
ND
NH
NJ
NM
NV
NY
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VA
VT
WA
WI
WV
WY
Number of
Facilities
1
1
4
1
1
6
8
3
24
19
3
1
20
2
12
27
1
24
1
10
18
5
2
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
45
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Exhibit 18
Releases for Lumber and Wood Products (SIC 24) in TRI, by Number of Facilities
(Releases reported in pounds/year)
Chemical Name
Arsenic Compounds
Chromium Compounds
Copper Compounds
Formaldehyde
Creosote
Arsenic
Copper
Chromium
Pentachlorophenol
SulfuricAcid
Ammonia
Mcthylcncbis
(Phenylisocyanate)
Phenol
Mcthanol
Toluene
Xylcne (Mixed Isomers)
Acetone
Methyl Ethyl Ketone
Phosphoric Acid
Hydrochloric Acid
Methyl Isobutyl Ketone
Zinc Compounds
Ammonium Sulfate
(Solution)
Glycol Ethers
N-Butyl Alcohol
Naphthalene
Anthracene
Dibcn/.ofuran
Ethylbenzene
Ethylcne Glycol
Nitric Acid
Quinolinc
Ammonium Nitrate
(Solution)
Antimony Compounds
Butyl Benzyl Phthalate
Chlorine
Di(2-Ethylhexyl) Phthalate
Dibutyl Phthalate
Dichloromethane
Methyl Methacrylate
Styrcnc
Tetrachlorocthylene
Tolucne-2,4-Diisocyanate
Zinc (Fume Or Dust)
Totals
ft/Facilities
Reporting
Chemical
225
223
222
69
68
66
65
63
36
25
24
24
18
14
14
12
10
9
9
8
8
5
4
4
4
4
3
3
2
2
2
2
1
1
1
1
1
1
491
Fugitive
Air
392
397
397
318332
377646
270
265
255
5605
10
361205
658
20855
130145
215435
52437
205915
8469
0
0
70864
0
0
34600
3199
10529
2000
850
1300
1000
0
272
0
0
5
5
0
0
37000
250
0
2
68
5
1,860,637
Point Air
387
392
397
1832467
641954
260
260
245
4206
48151
264070
9857
210255
554849
715331
1005851
180720
481703
20
0
121782
0
0
65400
89582
4852
0
0
64644
52900
1173
0
0
0
5
0
0
0
0
0
0
36529
5
6,388,247
Water
Discharges
1661
2043
2098
3500
8016
1451
1192
1779
2531
10
78011
0
2850
0
0
0
0
0
0
0
0
255
5
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
5
105,417
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
5
0
5
1333
943
5
250
0
255
0
7460
0
5
8
0
0
0
0
0
0
0
5
0
0
0
1
1
1
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
10,278
Total
Releases
2445
2832
2897
2155632
1028559
1986
1967
2279
12597
48171
710746
10515
233965
685002
930766
1058288
386635
490172
20
0
192646
260
5
100000
92781
15382
2001
851
65944
53900
1173
273
0
0
10
15
0
0
37000
250
0
2
36597
15
8,364,579
Average
Releases
per
Facility
11
13
13
31241
15126
30
30
36
350
1927
29614
438
12998
48929
66483
88191
38664
54464
2
0
24081
52
1
25000
23195
3846
667
284
32972
26950
587
137
0
0
10
15
0
0
37000
250
0
2
36597
15
17,036
Source: U.S. EPA, Toxics Release Inventory Database, LW6.
SIC Code 24
46
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Exhibit 19
Transfers for Lumber and Wood Product (SIC 24) in TRL by Number of Facilities
(Transfers reported in pounds/year)
Chemical Name
Arsenic Compounds
Chromium Compounds
Copper Compounds
Formaldehyde
Creosote
Arsenic
Copper
Chromium
Pentachlorophenol
Sulfuric Acid
Ammonia
Methylenebis
(Phenylisocyanate)
Phenol
Methanol
Toluene
Xylene (Mixed Isomers)
Acetone
Methyl Ethyl Ketone
Phosphoric Acid
Hydrochloric Acid
Methyl Isobutyl Ketone
Zinc Compounds
Ammonium Sulfate (Solution)
Glycol Ethers
N-Butyl Alcohol
Naphthalene
Anthracene
Dibenzofuran
Ethylbenzene
Ethylene Glycol
Nitric Acid
Quinoline
Ammonium Nitrate (Solution)
Antimony Compounds
Butyl Benzyl Phthalate
Chlorine
Di(2-Ethylhexyl) Phthalate
Dibutyl Phthalate
Dichloromethane
Methyl Methacrylate
Styrene
Tetrachloroethylene
Toluene-2,4-Diisocyanate
Zinc (Fume Or Dust)
Totals
# Facilities
Reporting
Chemical
225
223
222
69
68
66
65
63
36
25
24
24
18
14
14
12
10
9
9
8
8
5
4
4
4
4
3
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
491
POTW
Disharges
0
0
0
120
11502
16
35
7
1125
0
72250
600
750
598
0
5
0
0
250
0
0
0
0
3060
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
300
0
0
0
5
90,623
Disposal
90677
82702
77164
1304
1296906
81038
54935
99933
34860
1775
511
15
2550
4300
1700
1505
5
1,831,880
Recycling
18667
1010
500
4700
4800
16333
1800
750
1737
50,297
Treatment
11192
9494
9123
750
446558
11910
8090
16200
68963
1300
1100
17700
1750
250
250
751
255
751
251
250
606,888
Energy
Recovery
195
636818
40981
5800
43400
78619
9242
25990
109577
4500
9447
3420
750
968,739
Total
Transfers
101869
92446
86287
2369
2410451
92964
63060
1 16390
146939
0
74025
2411
2365
13648
70200
96707
9242
29490
250
0
109577
1755
0
7560
10447
751
255
751
5157
0
0
251
0
0
0
0
0
0
750
300
250
0
0
10
3,548,927
Average
Transfers
per
Facility
453
415
389
34
35448
1409
970
1847
4082
0
3084
100
131
975
5014
8059
924
3277
28
0
13697
351
0
1890
2612
188
85
250
2579
0
0
126
0
0
0
0
0
0
750
300
250
0
0
10
7,228
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
47
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
IV.B. Summary of Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate
information for the top chemicals (by weight) that facilities within this
sector self-reported as released to the environment based upon 1993
TRI data. Because this section is based upon self-reported release data,
it does not attempt to provide information on management practices
employed by the sector to reduce the release of these chemicals.
Information regarding pollutant release reductions over time may be
available from EPA's TRI and 33/50 programs, or directly from the
industrial trade associations that are listed in Section IX of this
document. Since these descriptions are cursory, please consult the
sources referenced below for a more detailed description of both the
chemicals described in this section, and the chemicals that appear on
the full list of TRI chemicals appearing in Section IV.A.
The brief descriptions provided below were taken from the 1993 Toxics
Release Inventory Public Data Release (EPA, 1994), the Hazardous
Substances Data Bank (HSDB), and the Integrated Risk Information
System (IRIS), both accessed via TOXNET1. The information contained
below is based upon exposure assumptions that have been conducted
using standard scientific procedures. The effects listed below must be
taken in context of these exposure assumptions that are more fully
explained within the full chemical profiles in HSDB.
1 TOXNET is a computer system run by the National Library of Medicine that includes a number of
toxicological databases managed by EPA, National Cancer Institute, and the National Institute for
Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line at
1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research
Information System), DART Pevelopmental and Reproductive Toxicity Database), DBIR (Directory of
Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center
Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS
(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and
TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and use, chemical and physical properties, safety and handling, toxicity and biomedical
effects, pharmacology, environmental fate and exposure potential, exposure standards and regulations,
monitoring and analysis methods, and additional references.
SIC Code 24
48
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Acetone
The top TRI releases for the lumber and wood products industry
24) as whole include:
Acetone
Ammonia
Creosote
Formaldehyde
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Phenol
Toluene
Xylenes (mixed isomers).
Toxicity. Acetone is irritating to the eyes, nose, and throat. Symptoms
of exposure to large quantities of acetone may include headache,
unsteadiness, confusion, lassitude, drowsiness, vomiting, and
respiratory depression.
Reactions of acetone (see environmental fate) in the lower atmosphere
contribute to the formation of ground-level ozone. Ozone (a major
component of urban smog) can affect the respiratory system, especially
in sensitive individuals such as asthmatics or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. If released into water, acetone will be degraded by
microorganisms or will evaporate into the atmosphere. Degradation
by microorganisms will be the primary removal mechanism.
Acetone is highly volatile, and once it reaches the troposphere (lower
atmosphere), it will react with other gases, contributing to the
formation of ground-level ozone and other air pollutants. EPA is
reevaluating acetone's reactivity in the lower atmosphere to determine
whether this contribution is significant.
Physical Properties. Acetone is a volatile and flammable organic
chemical.
Note: Acetone was removed from the list of TRI chemicals on June 16,
1995 (60 FR 31643) and will not be reported for 1994 or subsequent years.
September 1995
49
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Ammonia
Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose,
throat, and upper respiratory system.
Ecologically, ammonia is a source of nitrogen (an essential element for
aquatic plant growth), and may therefore contribute to eutrophication
of standing or slow-moving surface water, particularly in nitrogen-
limited waters such as the Chesapeake Bay. In addition, aqueous
ammonia is moderately toxic to aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Ammonia combines with sulfate ions in the
atmosphere and is washed out by rainfall, resulting in rapid return of
ammonia to the soil and surface waters.
Ammonia is a central compound in the environmental cycling of
nitrogen. Ammonia in lakes, rivers, and streams is converted to
nitrate.
Physical Properties. Ammonia is a corrosive and severely irritating gas
with a pungent odor.
Formaldehyde
Toxicity. Ingestion of formaldehyde leads to damage to the mucous
membranes of mouth, throat, and intestinal tract; severe pain,
vomiting, and diarrhea result. Inhalation of low concentrations can
lead to irritation of the eyes, nose, and respiratory tract. Inhalation of
high concentrations of formaldehyde causes severe damage to the
respiratory system and to the heart, and may even lead to death. Other
symptoms from exposure to formaldehyde include: headache,
weakness, rapid heartbeat, symptoms of shock, gastroenteritis, central
nervous system depression, vertigo, stupor, reduced body temperature,
and coma. Repeated contact with skin promotes allergic reactions,
dermatitis, irritation, and hardening. Contact with eyes causes injuries
ranging from minor, transient injury to permanent blindness,
depending on the concentration of the formaldehyde solution. In
addition, menstrual disorders and secondary sterility have been
reported in women exposed to formaldehyde.
SIC Code 24
50
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Methanol
Carcinogenicity. Formaldehyde is a probable human carcinogen via
both inhalation and oral exposure, based on limited evidence in
humans and sufficient evidence in animals.
Environmental Fate. Most formaldehyde is released to the
environment as a gas, and is rapidly broken down by sunlight and
reactions with atmospheric ions. Its initial oxidation product, formic
acid, is a component of acid rain. The rest of the atmospheric
formaldehyde is removed via dry deposition, rain or dissolution into
surface waters. Biodegradation of formaldehyde in water takes place in
a few days. Volatilization of formaldehyde dissolved in water is low.
Bioaccumulation of formaldehyde does not occur.
When released onto the soil, aqueous solutions containing
formaldehyde will leach through the soil. While formaldehyde is
biodegradable under both aerobic and anaerobic conditions, its fate in
soil and groundwater is unknown.
Although formaldehyde is found in remote areas, it is probably not
transported there, but rather is likely a result of the local generation of
formaldehyde from longer-lived precursors which have been
transported there.
Toxicity. Methanol is readily absorbed from the gastrointestinal tract
and the respiratory tract, and is toxic to humans in moderate to high
doses. In the body, methanol is converted into formaldehyde and
formic acid. Methanol is excreted as formic acid. Observed toxic effects
at high dose levels generally include central nervous system damage
and blindness. Long-term exposure to high levels of methanol via
inhalation cause liver and blood damage in animals.
Ecologically, methanol is expected to have low toxicity to aquatic
organisms. Concentrations lethal to half the organisms of a test
population are expected to exceed 1 mg methanol per liter water.
Methanol is not likely to persist in water or to bioaccumulate in aquatic
organisms.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Liquid methanol is likely to evaporate when left
exposed. Methanol reacts in air to produce formaldehyde which
contributes to the formation of air pollutants. In the atmosphere it can
react with other atmospheric chemicals or be washed out by rain.
September 1995
51
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Methanol is readily degraded by microorganisms in soils and surface
waters.
Physical Properties. Methanol is highly flammable.
Methvl Ethvl Ketone
Toluene
Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK)
for short periods of time can cause adverse effects on the nervous
system ranging from headaches, dizziness, nausea, and numbness in
the fingers and toes to unconsciousness. Its vapors are irritating to the
skin, eyes, nose, and throat and can damage the eyes. Repeated
exposure to moderate to high amounts may cause liver and kidney
effects.
Carcinogenicity. No agreement exists over the carcinogenicity of MEK.
One source believes MEK is a possible carcinogen in humans based on
limited animal evidence. Other sources believe that there is
insufficient evidence to make any statements about possible
carcinogenicity.
Environmental Fate. Most of the MEK released to the environment
will end up in the atmosphere. MEK can contribute to the formation
of air pollutants in the lower atmosphere. It can be degraded by
microorganisms living in water and soil.
Physical Properties. Methyl ethyl ketone is a flammable liquid.
Toxicity. Inhalation or ingestion of toluene can cause headaches,
confusion, weakness, and memory loss. Toluene may also affect the
way the kidneys and liver function.
Reactions of toluene (see environmental fate) in the atmosphere
contribute to the formation of ozone in the lower atmosphere. Ozone
can affect the respiratory system, especially in sensitive individuals
such as asthma or allergy sufferers.
Some studies have shown that unborn animals were harmed when
high levels of toluene were inhaled by their mothers, although the
same effects were not seen when the mothers were fed large quantities
of toluene. Note that these results may reflect similar difficulties in
humans.
SIC Code 24
52
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases of toluene to land and
water will evaporate. Toluene may also be degraded by
microorganisms. Once volatized, toluene in the lower atmosphere
will react with other atmospheric components contributing to the
formation of ground-level ozone and other air pollutants.
Physical Properties. Toluene is a volatile organic chemical.
Xylene (Mixed Isomers)
Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
ingestion, or skin contact. Short-term exposure of humans to high
levels of xylenes can cause irritation of the skin, eyes, nose, and throat,
difficulty in breathing, impaired lung function, impaired memory, and
possible changes in the liver and kidneys. Both short- and long-term
exposure to high concentrations can cause effects such as headaches,
dizziness, confusion, and lack of muscle coordination. Reactions of
xylenes (see environmental fate) in the atmosphere contribute to the
formation of ozone in the lower atmosphere. Ozone can affect the
respiratory system, especially in sensitive individuals such as asthma
or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases to land and water will
quickly evaporate, although some degradation by microorganisms will
occur.
Xylenes are moderately mobile in soils and may leach into
ground water, where they may persist for several years.
Xylenes are volatile organic chemicals. As such, xylenes in the lower
atmosphere will react with other atmospheric components,
contributing to the formation of ground-level ozone and other air
pollutants.
September 1995
53
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
IV.C. Other Data Sources
The Aerometric Information Retrieval System (AIRS) contains a wide
range of information related to stationary sources of air pollution,
including the emissions of a number of air pollutants which may be of
concern within a particular industry. With the exception of volatile
organic compounds (VOCs), there is little overlap with the TRI
chemicals reported above. Exhibit 20 summarizes annual releases of
carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter of 10
microns or less (PM10), total particulates (PT), sulfur dioxide (SO2), and
volatile organic compounds (VOCs).
Exhibit 20
Pollutant Releases (Short Tons/Years)
Industry
US Total
Metal Mining
Nonmetal Mining
Lumber and Wood
Products
Wood Furniture and
Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastic
Products
Stone, Clay, Glass, and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics
Motor Vehicles, Bodies,
Parts, and Accessories
CO
97,208,000
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
367
35,303
101
NO2
23,402,000
28,583
28,804
42,658
2,981
394,448
4,915
108,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
1,129
23,725
179
PMio
45,489,000
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
207
2,406
3
PT
7,836,000
140,052
167,948
63,761
3,178
113,571
1,031
39,082
44,860
36,877
5,355
171,853
83,017
22,490
3,136
293
12,853
28
S02
21,888,000
84,222
24,129
9,149
1,606
341,002
1,728
182,189
132,459
648,153
29,364
339,216
238,268
373,007
4,019
453
25,462
152
voc
23,312,000
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
309,058
140,741
30,262
82,292
27,375
102,186
4,854
101,275
7,310
Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
SIC Code 24
54
September 1995
-------
Sector Notebook. Project
Lumber and Wood Products
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of pollutant
release and transfer data across industrial categories. It is provided to
give a general sense as to the relative scale of releases and transfers
within each sector profiled under this project. Please note that the
following table does not contain releases and transfers for industrial
categories that are not included in this project, and thus cannot be used
to draw conclusions regarding the total release and transfer amounts
that are reported to TRL Similar information is available within the
annual TRI Public Data Release book.
Exhibit 21 is a graphical representation of a summary of the 1993 TRI
data for the Lumber and Wood Products Industry and the other sectors
profiled in separate notebooks. The bar graph presents the total TRI
releases and total transfers on the left axis and the triangle points show
the average releases per facility on the right axis. Industry sectors are
presented in the order of increasing total TRI releases. The graph is
based on the data shown in Exhibit 22 and is meant to facilitate
comparisons between the relative amounts of releases, transfers, and
releases per facility both within and between these sectors. The reader
should note, however, that differences in the proportion of facilities
captured by TRI exist between industry sectors. This can be a factor of
poor SIC matching and relative differences in the number of facilities
reporting to TRI from the various sectors. In the case of Lumber and
Wood Products Industry, the 1993 TRI data presented here covers 491
facilities. These facilities listed SIC 24 Lumber and Wood Products as a
primary SIC code.
September 1995
55
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
I
D
mic
§
ted
•
ber
SIC Code 24
56
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
cn
vU
•5
en
ected Indu
^^^
CD
o
Vs* ^^H
^S|
, t TO
JD ^
*r*
If
c
i— i
rt
III!
H
0
i— t
S3
n
Ss *
OS
1-1
a 1*1
£ 3 a a
53 2 "3 3
^ S « o
P4
oj a
11 1
&H
^
U
00
Industry Sector
o
o
vo"
CM
oo
CM
O
o
cn"
CM
CM
m
OS
00
^f.
VO
vo
CM
cn
vo
CM
en
a
II Stone, Clay, and Concre
o
o
£
ON
1-1
OO
•^
v>
m
vo
VH
OO
T— 1
^3.
^
-a
«
|| Lumber and Wood Pr<
o
CD
o
oo
-=!•
vo
m
in
•sf
en
CM
•si-'
en
oo
00
•3-
cn
CM
§
en
i — i
en
in
CM
Furniture and Fktures
^^
O
2
t~
VO
•sr
0
o
o
CM"
en
r-
CM
o
1 — 1
o
in
r~H
in
vo
en
00
en
OS
oo
CM
^
CM
U)
1=
1
o
o
o
2
t^
•n
-
1— 1
T-H
1 1
O
,--(
f-
VO
VO
o
vo
en
Electronic Equipment
o
o
s
•si-
en
en
oo
CM
O
in
VO
oo
(^
00
T,
1 — 1
0
en
o
Rubber and Misc. Plasti
o
o
0
OS
en
oq
CM
CM
OO
en
oo
en
CM
i
oo
in
»— i
o
en
en
OS
f~
O
VO
r^
en
PH
1 Motor Vehicle, Bodies,
and Accessories
0
o
o
VO
o
*-!
oo
CM
o
oo
0
»n
oo
o
o
0
OS
in
OS
vo
o
cn
cn
CM
^
VO
CM
1
O.
2
0
o
o
o
t~:
S
o
o
0
VO
CM
0
0
0
'^~
CM
cn
vo
r^
m
m
m
OS
00
CM
oo
CM
Inorganic Chem. Mfg.
O
o
oo
oo
en"
Os
oo
o
vo
vS
CM"
in
o
0
cs
^J-
en
vo
vo
m
, — i
Os
CM
Petroleum Refining
0
O
O
en
CM
i — i
*-;
c — •
vo
CM
CM
O
oo
CM
00
t-;
in
,0s
VO
o
en
o
CM
en
vo
CM
^
en
Fabricated Metals
O
o
0
•n
CM
,—t
en
in
vo
o
1
1
o
o
0
m
CM
CM
00
in
oo
oo
en
en in
~H CM
en en
en en
2 CM*
en en
en en
Iron and Steel
O
O
O
§
r— <
t-;
00
CM
m
en
en
^t-
CM
oo
OS
OS
VO
CM
l>
t^
00
m
CM
oo
oo
en
en
cn"
en
en
Nonferrous Metals
0
O
O
•n
r«4
•*
OO
en
0
o
o
oo
00
vo
vo
00
CM
O
o
o
VO
en
vo
in
^
Os
VO
oo
CM
VO
oo
CM
Organic Chemical Mfg.
M
.g
O
P-
1
r-i
;tor not subject t<
«
cfl
1
3
d
k— I
o
•""*
Metal Mining
&i
c
'•g
I
o
;tor not subject t<
&
w
!
P3
^^
^J-
•"^
Nonmetal Mining
1
1
rs
:tor not subject t(
«
cn
'O
f^
>~^
vo"
CM OO
•n"P
r^
Dry Cleaning
i!
tory Database, 1
K
1
Q
Q)
""S
ft!
.3
^
^
§
1
September 1995
57
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place.
Some companies have creatively implemented pollution prevention
techniques that improve efficiency and increase profits while at the
same time minimizing environmental impacts. This can be done in
many ways such as reducing material inputs, re-engineering processes
to reuse by-products, improving management practices, and employing
substitution of toxic chemicals. Some smaller facilities are able to
actually get below regulatory thresholds just by reducing pollutant
releases through aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both
general and company-specific descriptions of some pollution
prevention advances that have been implemented within the lumber
and wood products industry. While the list is not exhaustive, it does
provide core information that can be used as the starting point for
facilities interested in beginning their own pollution prevention
projects. When possible, this section provides information from real
activities that can, or are being implemented by this sector — including
a discussion of associated costs, time frames, and expected rates of
return. This section provides summary information from activities
that may be, or are being implemented by this sector. When possible,
information is provided that gives the context in which the techniques
can be effectively used. Please note that the activities described in this
section do not necessarily apply to all facilities that fall within this
sector. Facility-specific conditions must be carefully considered when
pollution prevention options are evaluated, and the full impacts of the
change must examine how each option affects, air, land, and water
pollutant releases.
Surface Protection
Several alternative manufacturing methods are part of the industry's
pollution prevention efforts. One common alternative is to replace
chemical treatment with another type of treatment to achieve surface
protection. For example, the need for surface treatment would be
decreased if efforts were made to dry the wood to reduce water content
(high water content leads to sapstain). Due to economies of scale, this
option may not be economically viable for a smaller mill.
Another pollution prevention option is the use of high velocity spray
systems that generate fewer process residuals and less drippage.
However, a small production volume may not favor this option since
spray systems require a larger flow of wood through the systems to be
economically or technically feasible.
SIC Code 24
58
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Other pollution prevention strategies relating to surface protection
include: 1) local and general ventilation within the cutting process
area to reduce dust which would accumulate on wood; 2) blowing
wood with air to further reduce sawdust on wood prior to surface
protection; and 3) the use of drainage collection devices on roof tops to
keep rainwater away from process wastes. For wastes that cannot be
reduced at the source, generators may consider used surface protectant
recycling as the next best option.
Panel Products
Air emissions from panel manufacturing are significantly greater than
releases to water or land. The following information on pollution
prevention options for the wood panel products industry (including
veneer/plywood and reconstituted wood products) is from Martin and
Northeim's summary.
Alternative Fiber Sources
One pollution prevention opportunity for the reconstituted wood
panel industry is to search for alternative sources of wood fiber. This
can be done in two ways: utilizing recycled wood waste and using
existing agricultural fibers.
Increasing prices for raw wood furnish have led some firms to develop
programs to recycle wood waste into chips for PB production. These
firms collect construction site debris, discarded household items, crates,
and used pallets for eventual use as PB furnish. Beyond finding
sources, an ideal fiber recycling program includes extensive training
and research on what materials are suitable, careful quality control of
the recycled materials, and cleaning materials to remove foreign
matter. There are many hurdles to properly cleaning the material
because it is difficult to process different kinds of material and
maintain a quality product.
A second alternative source for fiber is agricultural fiber, which can
come from two sources: agricultural crops grown expressly for fiber
(e.g., kenaf and bagasse) and residues of crops grown for other purposes
(e.g., corn stalks/cobs and cotton stalks). Currently, two plants are being
built in the U.S. that will use agricultural fiber to manufacture
composite panels. In terms of potential availability, the amount of
residual fiber generated by U.S. agriculture far exceeds present and
future fiber requirements for composite panel manufacture. The
feasibility of such a substitution, however, depends on many factors
such as product quality, cost, and current uses of agriculture residues.
September 1995
59
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Alternative Adhesives
Other pollution prevention options in the panel products industry
involve adhesive substitution. This involves replacing existing
adhesives with less toxic formulations. There are a number of
innovative adhesive options currently available for use in the panel
products industry.
MDI Substitution
Based on price alone, there seems to be little incentive for
manufacturers to switch from PF or UP to MDI adhesives. However,
since the early 80's, one third of the OSB industry has switched from PF
to MDI adhesives. According to their manufacturers, there are several
environmental advantages to using these adhesives. Because MDI
adhesives are capable of bonding wood flakes with a higher moisture
content, less dryer energy is required to dry flakes suitable for MDI
bonding. Other advantages to using MDI adhesives are lower press
temperatures and shorter press cycles, both of which may lead to
reduced press emissions. However, there are other concerns with
respect to the use of MDI adhesives. Some companies are opposed to
MDI substitution for reasons such as worker toxics exposure, potential
acute impacts of possible spills, and inconsistency with toxic use
reduction objectives. Manufacturers of MDI state that safe exposure
levels are obtainable through good engineering controls which include
making sure that blenders are well sealed, and that the blending and
forming areas are well ventilated.
High Moisture Adhesives
Switching to an adhesive that is capable of bonding a high moisture
furnish eliminates the need to dry wood to a low moisture content.
Dryer energy and temperature can be reduced because less water must
be removed from the wood. Press temperature can also be lowered
since heat transfer is more efficient in high moisture furnish, reducing
VOC emissions.
The gluing of high moisture content wood has become an established
practice in plywood manufacture. Many OSB plants are switching to
high moisture bonding adhesives with the primary goals of reducing
dryer emissions and possibly reducing wood drying costs. Efforts have
been made to improve phenolic resin technology to allow better
bonding in the presence of water. The primary incentive for bonding
high moisture veneer is a reduction in adhesive consumption. In the
Southern plywood industry; where dryout is a problem, a dramatic
SIC Code 24
60
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
reduction in adhesive use has been achieved by gluing high moisture
veneer.
Naturally-derived Adhesives
Spurred by rapid price increases of petroleum-derived chemicals in
adhesives such as PF and UP, chemical material suppliers, forest
products companies, and wood adhesive/binder suppliers are
expending research and development funds to search for renewable
raw material sources. Substitutes could replace entirely, or at least
partially, petroleum-derived chemicals now used in the manufacture
of wood adhesives. Naturally-derived adhesives are included in this
profile as a pollution prevention opportunity because of the potential
to use renewable resources, which in many cases are by-products of
other processes.
Furfuryl Alcohol Resins
Resins manufactured from furfuryl alcohol are being evaluated as an
alternative low-VOC binder to substitute for PF resins. Unlike PF
resins, furfuryl alcohol resins are stored stable at ambient temperatures,
without refrigeration. As delivered, furfuryl alcohol resin contains
very low amounts of volatile components. Upon curing, it reduces 80
to 90 percent of total VOC emissions, and reduces Hazardous Air
Pollutants (HAPs) by the same amount. The furfuryl alcohol system
offers the same relative speed of cure as the PF resin systems.
Furfuryl alcohol resin is currently in the experimental stage of
development. The industry has shown little interest in the resin
because of its high cost; which is twice that of a PF resin. However, cost
analyses performed for the insulation industry show that using the
resin to meet future HAP standards is cheaper than purchasing and
operating control devices such as scrubbers. The same is likely true for
the wood products industry.
Lignin Adhesives
Lignin is an aromatic polymer that makes up one of the three major
components of wood (cellulose and hemicellulose are the others). The
abundance of lignin as a waste product in pulp mills has made it a
desirable raw material alternative to nonrenewable petroleum-derived
chemicals in the production of wood adhesives.
Until recently, no more than 20 to 30 percent of lignin could be
substituted into PF resins because cure times increased as the amount
of lignin increased. Another drawback is that lignin adhesives have
September 1995
61
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
low cross-linking and strength. However, a new approach has recently
been developed that can substitute large amounts of kraft lignin for PF
adhesives while actually increasing cure speed and board strength.
Currently, Westvaco is the only company in the U.S. that operates a
commercial lignin extraction facility. The capital cost of a new
commercial lignin extraction facility compared to the capital cost of a
new phenol plant is estimated to be almost equal per pound of product
produced. However, because the selling price of lignin is only $0.32-
0.34, compared to the selling price of phenol which is $.45/solid pound
and rising, there is more of an economic incentive to build a new
phenol plant than a lignin extraction facility.
Polyvinyl acetate (PVA)
There have been some mill trials and some small quantities of
hardwood plywood made with cross-linked polyvinyl acetate (PVA)
adhesives. Blends of PVA and UF are also sometimes used in the
manufacture of hardwood plywood. Cross-linked PVAs are light in
color, are compatible with the hardwood plywood manufacturing
process, and don't require additional equipment. Concerns have been
expressed about the potential of airborne release of vinyl monomers.
PVA adhesives are considerably higher in cost than UF adhesives.
Alternative Manufacturing Processes
Veneer and Plywood Adhesive Reduction
In the softwood plywood industry, a common waste generated by the
typical spray-line layup system is over-spray. A more efficient way of
applying adhesive to veneer is by foam extrusion, a process in which
foamed adhesive is forced under pressure to the extrusion head. This
process better concentrates the glue stream onto the veneer, resulting
in less wasted adhesive and less chance of adhesive dryout before
pressing. In terms of economics, the combination of less waste and
lower spread rates when using foam extruders can add up to savings in
the 20 to 31 percent range, depending on the type of equipment used.
Another pollution prevention option in the softwood plywood
industry is the variable application rate strategy (VARS). The amount
of adhesive required to bond veneer varies with moisture content. For
example, high moisture veneer requires less glue than low moisture
veneer because there is less migration of water from the glue into the
veneer. Although the moisture content of veneer varies at a typical
plywood mill, glue is applied at a constant rate to prevent dryout of low
moisture veneer. A 1992 study by Faust and Borders outlined in Forest
SIC Code 24
62
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Products Journal, investigated the use of the glue application rate with
respect to improved bond quality and reduced resin consumption. The
variable application rate strategy (VARS) they developed adjusted the
glue spread rate for each individual plywood panel according to its
moisture content. Process-sensing and control technology has been
developed for the practical application of VARS. Sensor technology is
currently available for on-line adjustment and measurement of veneer
moisture content and temperature. In addition to compensating for
problem bonding conditions that occur unexpectedly during
production, the greatest benefit of VARS from a pollution prevention
standpoint is a reduction in adhesive consumption and, consequently a
reduction in plant emissions.
Alternative Dryers
There are other process modifications that may be implemented to
reduce emissions while drying green furnish for reconstituted wood
panel manufacture. Researchers are currently investigating the use of
alternative drying methods for raw wood furnish.
Rotary drum dryers are used in the OSB industry. These are typically
characterized by high-temperature drying air, aggressive handling of
strands, and short product-retention times. The adverse affects of these
characteristics include VOC emissions and strand degradation.
Research has shown that low-temperature drying reduces VOC
emissions. However, this requires that the furnish be retained in the
dryer for a longer period of time which is difficult to achieve in a rotary
dryer. It has been found that conveyor belt dryers generate less VOC
emissions than rotary dryers. Temperatures of less than 400°F and very
low volumes of exhaust gases are possible with conveyor dryers,
resulting in low emission levels of VOC, while virtually eliminating
strand damage within the dryer. Conveyor dryers can also be used to
dry PB furnish.
The three pass high velocity (3PHV) rotary drum dryer is a major
breakthrough in rotary drum drying technology that has the potential
to reduce VOC emissions significantly (see Exhibit 9). The 3PHV is a
rotating cylindrical drum consisting of three, concentric, interlocking
cylinders. Hot gases enter the outermost cylinder with the wood chips
and progress through the intermediate and then the inner drum shells
in a serpentine flow path. This flow path direction is the opposite of
that in the conventional three-pass dryer. This reverse air flow may
reduce VOC emissions.
In the first pass, the 3PHV dryer allows smaller, dried particles to pass
through the slower moving mass of larger, wetter particles in an area
September 1995
63
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
bounded by the outer and intermediate drum cylinders. This area is
much larger than the area of the inner drum of conventional triple
pass dryers. As the larger particles are dried, they will "catch up" with
the smaller faster moving particles in an area bounded by the
intermediate (second pass) drum cylinder. Here, airflow velocities
become high enough to convey the entire mass of particles out of the
drying portion of the drum and into the inner (third pass) drum
cylinder where they will be conveyed out of the dryer. This action
prevents the product from reaching temperatures in excess of the wet
bulb temperature, thus reducing carbon monoxide and hydrocarbon
emissions associated with pyrolysis and combustion of the wood chips.
Wood Preserving
Water-borne preservatives produce less waste than oil-borne
preservatives because process wastewater is reused rather than
discharged. In addition, well designed treatment plants, good
treatment practices, effective housekeeping, and employee training also
help reduce waste at the source.
Well designed treatment plants may have enclosed treatment
buildings, covered drip pads with liners, automatic lumber handling
systems, centralized tank farms with spill containment, and air
ventilation systems. The RCRA standards in 40 CFR 264 and 265
require that drip pads must contain drippage, be free of cracks and gaps,
and be cleaned and inspected. Plants can also be designed to minimize
mist or droplet emissions from cylinders and work tanks through the
use of air exchange systems and cylinder and tank venting.
Treatment practices are also important for preventing pollution.
Ensuring that wood stock is clean prior to treatment will prevent dirt,
sawdust, and other debris from accumulating in the treatment system.
To prevent debris buildup, wood can be covered during shipment
and/or power-washed when necessary before it enters the treatment
plant. Strip pumps may be installed to continuously return residual
chemical solutions to the work tank, resulting in less dripping when
the cylinder doors are opened. If treating cylinders are tilted slightly
away from the drip pad, there is also less spillage when opening the
cylinder doors.
Housekeeping is an integral part of waste minimization efforts. All
tanks, mixing systems, treating cylinders, drip pads, and spill
containments should be inspected regularly for leaks. Drip pads and
collection areas should be kept clean. Storage yards should be inspected
daily, and any drippage detected should be cleaned up within 24 hours.
SIC Code 24
64
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Several other preservatives have been proposed as alternatives to
traditional preservatives. For example, wood can be treated with
borates using both pressure and non-pressure processes. However,
because they are highly susceptible to leaching, borates cannot be used
to preserve wood that will be in contact with the ground or exposed to
the weather (e.g., decking).
Ammoniacal copper/quarternary ammonium (ACQ) is another
proposed alternative. Initial above-ground field test data show that
ACQ is effective for softwood and hardwood protection. Other
alternative preservatives may include copper-8-quinolinolate (Cus),
copper naphthanate, zinc naphthanate, quarternary NHj compounds
(QAC), and zinc sulfate.
Treatment processes may vary in their ability to minimize waste. For
example, the empty-cell process uses less carrier oil than the full-cell
process for oil-borne preservatives. The modified full-cell treatment
reduces the uptake of treating solution and minimizes the amount of
dripping for water-borne preservatives.
Pollution Prevention Case Studies
Reconstituted Wood Products
By late 1995, CanFibre hopes to start up its first plant to produce MDF
using 100 percent post-consumer waste and PF adhesives. The plant
(the first of its kind in North America) will be located near Toronto,
Ontario. Approximately 1.2 million ft3 per year of structural MDF will
be produced from recycled urban waste such as waste wood, cardboard,
drink containers, newspaper, etc. The plant will have two significant
cost advantages over conventional MDF plants: (1) the costs of post-
consumer waste is currently negative, and (2) savings in freight costs
due to the plant's location near an urban site (most existing MDF
plants are remotely located and the cost of hauling wood waste back to
these mills is high). The net mill cost for the process used by the firm's
Toronto plant is estimated to be $183/million square feet (MSF) versus
$228/MSF for a conventional plant. The company plans to build a total
of nine plants in North America: six in the U.S. and three in Canada.
All plants will use 100 percent post-consumer waste and PF adhesives.
Wood Preserving
Perry Builders, Inc. employs 20 people at its Henderson pressure wood
preserving manufacturing facility. Perry Builders recognizes that each
wood treater has an important responsibility in properly handling and
September 1995
65
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
disposing of the wastes it produces and is committed to meeting this
challenge. Perry uses a water-borne chemical preservative; chromated
copper arsenate, to treat lumber, plywood, timbers, and other wood
products for decks, fences, and other outdoor uses. Hazardous waste
results from contact of sawdust, wood chips, and dirt with the
preservative. It has successfully minimized its hazardous waste
generation by 80 percent in two years with the implementation of a
low-cost waste minimization program. In 1987, Perry Builders
generated 15 drums of hazardous waste with a disposal cost of $2,380.
By 1989 Perry Builders reduced its disposal cost to $310 by generating
only two drums.
This reduction was achieved by changing both equipment and
processes to achieve a fully integrated closed system in which the
application, receipt, transfer, and storage of the preservation takes place
in a contained area.
The goal is to apply the preservative to the wood while minimizing
the loss of the preservative as a waste. By holding the lumber in the
treatment chamber longer to allow drippage, and by using a vacuum
pump to further dry the lumber, the treatment solution remains in the
chamber and does not come into contact with scrap material and dirt.
As an incentive to employees to assure adequate drying time,
management instituted pay based on hourly wages rather than an
amount of lumber treated. A roof over the area housing the treated
lumber prevents runoff during rainfall.
Perry Builders estimates that the cost of the vacuum pump, the roof,
and the increased drying time will be recovered in five years through
reduced disposal costs. There is also another economic benefit-since
the drier lumber weighs less, more footage of lumber can be shipped on
each truck, thereby reducing freight costs.
SIC Code 24
66
September 1995
-------
Sector Notebook. Project
Lumber and Wood Products
VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and regulations that may
apply to this sector. The purpose of this section is to highlight, and
briefly describe the applicable Federal requirements, and to provide
citations for more detailed information. The three following sections
are included.
• Section IV.A contains a general overview of major statutes
• Section FV.B contains a list of regulations specific to this industry
• Section IV.C contains a list of pending and proposed regulations
The descriptions within Section IV are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe
all applicable environmental requirements. Moreover, they do not
constitute formal interpretations or clarifications of the statutes and
regulations. For further information, readers should consult the Code
of Federal Regulations and other state or local regulatory agencies. EPA
Hotline contacts are also provided for each major statute.
VI.A. General Description of Major Statutes
Resource Conservation And Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976 which
amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and
hazardous (Subtitle C) waste management activities. The Hazardous
and Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's
waste management provisions and added Subtitle I, which governs
underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous
waste from the point of generation to disposal. RCRA hazardous
wastes include the specific materials listed in the regulations
(commercial chemical products, designated with the code "P" or "U";
hazardous wastes from specific industries/sources, designated with the
code "K"; or hazardous wastes from non-specific sources, designated
with the code "F") or materials which exhibit a hazardous waste
characteristic (ignitability, corrosivity, reactivity, or toxicity and
designated with the code "D").
September 1995
67
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and recordkeeping standards. Facilities
that treat, store, or dispose of hazardous waste must obtain a permit,
either from EPA or from a State agency which EPA has authorized to
implement the permitting program. Subtitle C permits contain general
facility standards such as contingency plans, emergency procedures,
recordkeeping and reporting requirements, financial assurance
mechanisms, and unit-specific standards. RCRA also contains
provisions (40 CFR Part 264 Subpart S and §264.10) for conducting
corrective actions which govern the cleanup of releases of hazardous
waste or constituents from solid waste management units at RCRA-
regulated facilities.
Although RCRA is a Federal statute, many States implement the
RCRA program. Currently, EPA has delegated its authority to
implement various provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any
company that transports, treats, stores, or disposes of hazardous waste.
Here are some important RCRA regulatory requirements:
• Identification of Solid and Hazardous Wastes (40 CFR Part 261)
lays out the procedure every generator should follow to
determine whether the material created is considered a
hazardous waste, solid waste, or is exempted from regulation.
• Standards for Generators of Hazardous Waste (40 CFR Part 262)
establishes the responsibilities of hazardous waste generators
including obtaining an ID number, preparing a manifest,
ensuring proper packaging and labeling, meeting standards for
waste accumulation units, and recordkeeping and reporting
requirements. Generators can accumulate hazardous waste for
up to 90 days (or 180 days depending on the amount of waste
generated) without obtaining a permit.
• Land Disposal Restrictions (LDRs) are regulations prohibiting
the disposal of hazardous waste on land without prior
treatment. Under the LDRs (40 CFR 268), materials must meet
land disposal restriction (LDR) treatment standards prior to
placement in a RCRA land disposal unit (landfill, land
treatment unit, waste pile, or surface impoundment). Wastes
subject to the LDRs include solvents, electroplating wastes,
heavy metals, and acids. Generators of waste subject to the LDRs
must provide notification of such to the designated TSD facility
to ensure proper treatment prior to disposal.
SIC Code 24
68
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
• Used Oil Management Standards (40 CFR Part 279) impose
management requirements affecting the storage, transportation,
burning, processing, and re-refining of the used oil. For parties
that merely generate used oil, regulations establish storage
standards. For a party considered a used oil marketer (one who
generates and sells off-specification used oil directly to a used oil
burner), additional tracking and paperwork requirements must
be satisfied.
• Tanks and Containers used to store hazardous waste with a high
volatile organic concentration must meet emission standards
under RCRA. Regulations (40 CFR Part 264-265, Subpart CC)
require generators to test the waste to determine the
concentration of the waste, to satisfy tank and container
emissions standards, and to inspect and monitor regulated units.
These regulations apply to all facilities who store such waste,
including generators operating under the 90-day accumulation
rule.
• Underground Storage Tanks (USTs) containing petroleum and
hazardous substance are regulated under Subtitle I of RCRA.
Subtitle I regulations (40 CFR Part 280) contain tank design and
release detection requirements, as well as financial responsibility
and corrective action standards for USTs. The UST program also
establishes increasingly stringent standards, including upgrade
requirements for existing tanks, that must be met by 1998.
• Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with strict design and
operating standards. BIF regulations (40 CFR Part 266, Subpart
H) address unit design, provide performance standards, require
emissions monitoring, and restrict the type Of waste that may be
burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations.
The RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST,
excluding Federal holidays.
Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), a 1980 law commonly known as Superfund,
authorizes EPA to respond to releases, or threatened releases, of
hazardous substances that may endanger public health, welfare, or the
environment. CERCLA also enables EPA to force parties responsible
for environmental contamination to clean it up or to reimburse the
Superfund for response costs incurred by EPA. The Superfund
September 1995
69
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Amendments and Reauthorization Act (SARA) of 1986 revised
various sections of CERCLA, extended the taxing authority for the
Superfund, and created a free-standing law, SARA Title III, also known
as the Emergency Planning and Community Right-to-Know Act
(EPCRA).
The CERCLA hazardous substance release reporting regulations (40
CFR Part 302) direct the person in charge of a facility to report to the
National Response Center (NRC) any environmental release of a
hazardous substance which exceeds a reportable quantity. Reportable
quantities are defined and listed in 40 CFR § 302.4. A release report
may trigger a response by EPA, or by one or more Federal or State
emergency response authorities.
EPA implements hazardous substance responses according to
procedures outlined in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP
includes provisions for permanent cleanups, known as remedial
actions, and other cleanups referred to as "removals." EPA generally
takes remedial actions only at sites on the National Priorities List
(NPL), which currently includes approximately 1300 sites. Both EPA
and states can act at other sites; however, EPA provides responsible
parties the opportunity to conduct removal and remedial actions and
encourages community involvement throughout the Superfund
response process.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, answers
questions and references guidance pertaining to the Superfund
program. The CERCLA Hotline operates weekdays from 8:30 a.m. to
7:30 p.m., EST, excluding Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
community access to information about chemical hazards and to
facilitate the development of chemical emergency response plans by
State and local governments. EPCRA required the establishment of
State emergency response commissions (SERCs), responsible for
coordinating certain emergency response activities and for appointing
local emergency planning committees (LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
four types of reporting obligations for facilities which store or manage
specified chemicals:
SIC Code 24
70
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
• EPCRA §302 requires facilities to notify the SERC and LEPC of
the presence of any "extremely hazardous substance" (the list of
such substances is in 40 CFR Part 355, Appendices A and B) if it
has such substance in excess of the substance's threshold
planning quantity, and directs the facility to appoint an
emergency response coordinator.
• EPCRA §304 requires the facility to notify the SERC and the LEPC
in the event of a release exceeding the reportable quantity of a
CERCLA hazardous substance or an EPCRA extremely
hazardous substance.
• EPCRA §§311 and 312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act,
is present in an amount exceeding a specified threshold to
submit to the SERC, LEPC, and local fire department material
safety data sheets (MSDSs) or lists of MSDSs and hazardous
chemical inventory forms (also known as Tier I and II forms).
This information helps the local government respond in the
event of a spill or release of the chemical.
• EPCRA §313 requires manufacturing facilities included in SIC
codes 20 through 39, which have ten or more employees, and
which manufacture, process, or use specified chemicals in
amounts greater than threshold quantities, to submit an annual
toxic chemical release report. This report, commonly known as
the Form R, covers releases and transfers of toxic chemicals to
various facilities and environmental media, and allows EPA to
compile the national Toxic Release Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA's EPCRA Hotline, at (800) 535-0202, answers questions and
distributes guidance regarding the emergency planning and
community right-to-know regulations. The EPCRA Hotline operates
weekdays from 8:30 a.m.. to 7:30 p.m., EST, excluding Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act,
commonly referred to as the Clean Water Act (CWA), is to restore and
maintain the chemical, physical, and biological integrity of the nation's
surface waters. Pollutants regulated under the CWA include "priority"
pollutants, including various toxic pollutants; "conventional"
pollutants, such as biochemical oxygen demand (BOD), total suspended
solids (TSS), fecal coliform, oil and grease, and pH; and "non-
September 1995
71
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
conventional" pollutants, including any pollutant not identified as
either conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA §402)
controls direct discharges into navigable waters. Direct discharges or
"point source" discharges are from sources such as pipes and sewers.
NPDES permits, issued by either EPA or an authorized State (EPA has
presently authorized forty States to administer the NPDES program),
contain industry-specific, technology-based and/or water quality-based
limits, and establish pollutant monitoring and reporting requirements.
A facility that intends to discharge into the nation's waters must obtain
a permit prior to initiating its discharge. A permit applicant must
provide quantitative analytical data .identifying the types of pollutants
present in the facility's effluent. The permit will then set forth the
conditions and effluent limitations under which a facility may make a
discharge.
A NPDES permit may also include discharge limits based on Federal or
State water quality criteria or standards, that were designed to protect
designated uses of surface waters, such as supporting aquatic life or
recreation. These standards, unlike the technological standards,
generally do not take into account technological feasibility or costs.
Water quality criteria and standards vary from State to State, and site to
site, depending on the use classification of the receiving body of water.
Most States follow EPA guidelines which propose aquatic life and
human health criteria for many of the 126 priority pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program
to address storm water discharges. In response, EPA promulgated the
NPDES storm water permit application regulations. Storm water
discharge associated with industrial activity means the discharge from
any conveyance which is used for collecting and conveying storm
water and which is directly related to manufacturing, processing or raw
materials storage areas at an industrial plant (40 CFR 122.26(b)(14)).
These regulations require that facilities with the following storm water
discharges apply for a NPDES permit: (1) a discharge associated with
industrial activity; (2) a discharge from a large or medium municipal
storm sewer system; or (3) a discharge which EPA or the State
determines to contribute to a violation of a water quality standard or is
a significant contributor of pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity"
means a storm water discharge from one of 11 categories of industrial
SIC Code 24
72
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
activity defined at 40 CFR 122.26. Six of the categories are defined by
SIC codes while the other five are identified through narrative
descriptions of the regulated industrial activity. If the primary SIC code
of the facility is one of those identified in the regulations, the facility is
subject to the storm water permit application requirements. If any
activity at a facility is covered by one of the five narrative categories,
storm water discharges from those areas where the activities occur are
subject to storm water discharge permit application requirements.
Those facilities/activities that are subject to storm water discharge
permit application requirements are identified below. To determine
whether a particular facility falls within one of these categories, the
regulation should be consulted.
Category i: Facilities subject to storm water effluent guidelines, new
source performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products (except
paperboard containers and products); SIC 28-chemicals and allied
products (except drugs and paints); SIC 29-petroleum refining; and SIC
311-leather tanning and finishing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that
receive or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts;
and SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC
41-local passenger transportation; SIC 42-trucking and warehousing
(except public warehousing and storage); SIC 43-U.S. Postal Service; SIC
44-water transportation; SIC 45-transportation by air; and SIC 5171-
petroleum bulk storage stations and terminals.
Category ix: Sewage treatment works.
September 1995
73
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products;
SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel
related products; SIC 2434-wood kitchen cabinets manufacturing; SIC
25-furniture and fixtures; SIC 265-paperboard containers and boxes; SIC
267-converted paper and paperboard products; SIC 27-printing,
publishing, and allied industries; SIC 283-drugs; SIC 285-paints,
varnishes, lacquer, enamels, and allied products; SIC 30-rubber and
plastics; SIC 31-leather and leather products (except leather and tanning
and finishing); SIC 323-glass products; SIC 34-fabricated metal products
(except fabricated structural metal); SIC 35-industrial and commercial
machinery and computer equipment; SIC 36-electronic and other
electrical equipment and components; SIC 37-transportation
equipment (except ship and boat building and repairing); SIC 38-
measuring, analyzing, and controlling instruments; SIC 39-
miscellaneous manufacturing industries; and SIC 4221-4225-public
warehousing and storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes
to a publicly-owned treatment works (POTWs). The national
pretreatment program (CWA §307(b)) controls the indirect discharge of
pollutants to POTWs by "industrial users." Facilities regulated under
§307(b) must meet certain pretreatment standards. The goal of the
pretreatment program is to protect municipal wastewater treatment
plants from damage that may occur when hazardous, toxic, or other
wastes are discharged into a sewer system and to protect the quality of
sludge generated by these plants. Discharges to a POTW are regulated
primarily by the POTW itself, rather than the State or EPA.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within
each category. "Categorical" pretreatment standards applicable to an
industry on a nationwide basis are developed by EPA. In addition,
another kind of pretreatment standard, "local limits," are developed by
the POTW in order to assist the POTW in achieving the effluent
limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the
NPDES or the pretreatment program, if it develops its own program, it
may enforce requirements more stringent than Federal standards.
SIC Code 24
74
September 1995
-------
Sector Motebook Project
Lumber and Wood Products
EPA's Office of Water, at (202) 260-5700, will direct callers with
questions about the CWA to the appropriate EPA office. EPA also
maintains a bibliographic database of Office of Water publications
which can loe accessed, through the Ground. Water and Drinking Water
resource center, at (202) 260-7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking
water. The law authorizes EPA to develop national drinking water
standards and to create a joint Federal-State system to ensure
compliance with these standards. The SDWA also directs EPA to
protect underground sources of drinking water through the control of
underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards
under its SDWA authority. EPA and authorized States enforce the
primary drinking water standards, which are, contaminant-specific
concentration limits that apply to certain public drinking water
supplies. Primary drinking water standards consist of maximum
contaminant level goals (MCLGs), which are non-enforceable health-
based goals, and maximum contaminant levels (MCLs), which are
enforceable limits set as close to MCLGs as possible, considering cost
and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR
Parts 144-148) is a permit program which protects underground sources
of drinking water by regulating five classes of injection wells. UIC
permits include design, operating, inspection, and monitoring
requirements. Wells used to inject hazardous wastes must also comply
with RCRA corrective action standards in order to be granted a RCRA
permit, and must meet applicable RCRA land disposal restrictions
standards. The UIC permit program is primarily State-enforced, since
EPA has authorized all but a few States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source
Aquifer program, which prohibits Federal funds from being expended
on projects that may contaminate the sole or principal source of
drinking water for a given area, and for a State-implemented Wellhead
Protection program, designed to protect drinking water wells and
drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at (800) .426-4791, answers
questions and distributes guidance pertaining to SDWA standards. The
September 1995
75
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Hotline operates from 9:00 a.m. through 5:30 p.m., EST, excluding
Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to
create a regulatory framework to collect data on chemicals in order to
evaluate, assess, mitigate, and control risks which may be posed by
their manufacture, processing, and use. TSCA provides a variety of
control methods to prevent chemicals from posing unreasonable risk.
TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA §5, EPA has established an inventory of chemical
substances. If a chemical is not already on the inventory, and has not
been excluded by TSCA, a premanufacture notice (PMN) must be
submitted to EPA prior to manufacture or import. The PMN must
identify the chemical and provide available information on health and
environmental effects. If available data are not sufficient to evaluate
the chemical's effects, EPA can impose restrictions pending the
development of information on its health and environmental effects.
EPA can also restrict significant new uses of chemicals based upon
factors such as the projected volume and use of the chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in
commerce, limit the use, require labeling, or place other restrictions on
chemicals that pose unreasonable risks. Among the chemicals EPA
regulates under §6 authority are asbestos, chlorofluorocarbons (CFCs),
and polychlorinated biphenyls (PCBs).
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances
Control Act standards. The Service operates from 8:30 a.m. through
4:30 p.m., EST, excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean Air
Act Amendments (CAAA) of 1990, are designed to "protect and
enhance the nation's air resources so as to promote the public health
and welfare and the productive capacity of the population." The CAA
consists of six sections, known as Titles, which direct EPA to establish
national standards for ambient air quality and for EPA and the States to
implement, maintain, and enforce these standards through a variety of
mechanisms. Under the CAAA, many facilities will be required to
obtain permits for the first time. State and local governments oversee,
SIC Code 24
76
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
manage, and enforce many of the requirements of the CAAA.
regulations appear at 40 CFR Parts 50-99.
CAA
Pursuant to Title I of the CAA, EPA has established national ambient
air quality standards (NAAQSs) to limit levels of "criteria pollutants,"
including carbon monoxide, lead, nitrogen dioxide, particulate matter,
ozone, and sulfur dioxide. Geographic areas that meet NAAQSs for a
given pollutant are classified as attainment areas; those that do not
meet NAAQSs are classified as non-attainment areas. Under §110 of
the CAA, each State must develop a State Implementation Plan (SIP) to
identify sources of air pollution and to determine what reductions are
required to meet Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance
Standards (NSPSs), which are nationally uniform emission standards
for new stationary sources falling within particular industrial
categories. NSPSs are based on the pollution control technology
available to that category of industrial source but allow the affected
industries the flexibility to devise a cost-effective means of reducing
emissions.
Under Title I, EPA establishes and enforces National Emission
Standards for Hazardous Air Pollutants (NESHAPs), nationally
uniform standards oriented towards controlling particular hazardous
air pollutants (HAPs). Title III of the CAAA further directed EPA to
develop a list of sources that emit any of 189 HAPs, and to develop
regulations for these categories of sources. To date EPA has listed 174
categories and developed a schedule for the establishment of emission
standards. The emission standards will be developed for both new and
existing sources based on "maximum achievable control technology"
(MACT). The MACT is defined as the control technology achieving the
maximum degree of reduction in the emission of the HAPs, taking
into account cost and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks,
buses, and planes. Reformulated gasoline, automobile pollution
control devices, and vapor recovery nozzles on gas pumps are a few of
the mechanisms EPA uses to regulate mobile air emission sources.
Title IV establishes a sulfur dioxide emissions program designed to
reduce the formation of acid rain. Reduction of sulfur dioxide releases
will be obtained by granting to certain sources limited emissions
allowances, which, beginning in 1995, will be set below previous levels
of sulfur dioxide releases.
September 1995
77
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One
purpose of the operating permit is to include in a single document all
air emissions requirements that apply to a given facility. States are
developing the permit programs in accordance with guidance and
regulations from EPA. Once a State program is approved by EPA,
permits will be issued and monitored by that State.
Title VI is intended to protect stratospheric ozone by phasing out the
manufacture of ozone-depleting chemicals and restrict their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), will be phased out entirely by the year
2000, while certain hydrochlorofluorocarbons (HCFCs) will be phased
out by 2030.
EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric
Ozone Information Hotline, at (800) 296-1996, provides general
information about regulations promulgated under Title VI of the CAA,
and EPA's EPCRA Hotline, at (800) 535-0202, answers questions about
accidental release prevention under CAA §112(r). In addition, the
Technology Transfer Network Bulletin Board System (modem access
(919) 541-5742)) includes recent CAA rules, EPA guidance documents,
and updates of EPA activities.
VLB. Industry Specific Requirements
Clean Air Act (CAA)
Under the Clean Air Act, PMio, (particulate matter with an
aerodynamic diameter of 10 microns or less) and volatile organic
compounds (VOCs) are regulated to ensure attainment with the
National Ambient Air Quality Standards for PMio and ground level
ozone (VOCs contribute to the formation of ground level ozone).
Wood products have the potential to emit PMio and VOCs in
significant quantities.
As required by §110 of the CAA, State Implementation Plans (SIPs)
must be developed to identify sources of air pollution and determine
what reductions are required to meet Federal standards. An important
compliance component of these SIPs are generic opacity limits, which
dictate that no stack shall have emissions above a certain percent
opacity. Within the wood products industry, these regulations apply to
hog fuel boilers and veneer dryers. The standard limit for emissions of
all kinds is 20 percent opacity, meaning that only 80 percent of light is
SIC Code 24
78
September 1995
-------
Secto* Notebook. Project
Lumber and Wood Products
able to pass through the plume. However, some States provide
exceptions to the opacity limits for certain industries or manufacturing
processes depending on the state's SIP.
Also written into each SIP are provisions that require all new
stationary sources constructed in a National Ambient Air Quality
Standards (NAAQ) attainment area and that have the potential to emit
above a specified tonnage per year to install best available control
technology (BACT). In addition, these facilities need to obtain a
Prevention of Significant Deterioration (PSD) permit (40 CFR 52.21).
Standards of Performance for Fossil Fuel Fired Steam Generating Units
(40 CFR 60.40, subpart D), apply to any fossil fuel-fired and wood
residue fired steam generating unit that commences construction
modification or reconstruction after August 17, 1971, and that has a
heat input capacity derived from fossil fuels of greater than 73
megawatts (250 mm BTU/hr). Unlike subparts Db and DC, descriptions
of which follow, the contribution of heat from wood fuels is not
considered in determining the heat input capacity since it is not a fossil
fuel. The regulation addresses emission standards, compliance and
performance test methods, monitoring requirements (including
continuous opacity monitoring systems), and reporting requirements
for particulate matter, nitrogen oxides, and sulfur dioxide.
Standards of Performance for Industrial-Commercial-Institutional
Steam Generating Units (40 CFR 60.40b, subpart Db), apply to any steam
generating unit that commences construction, modification, or
reconstruction after June 19, 1984 and that has a heat input (heat
derived from combustion of fuel only, not exhaust gases, etc.) capacity
of at least 29 MW. This includes steam generating units that use wood
as a source of fuel. The regulation addresses emission standards,
compliance and performance test methods, monitoring requirements,
and reporting requirements for particulate matter, nitrogen oxides, and
sulfur dioxide. Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating Units (40 CFR 60.40c,
Subpart DC), apply to any small steam generating unit (2.9 MW to 29
MW) that commences construction, modification, or reconstruction,
after June 9, 1989. The regulation addresses requirements for
particulate matter and sulfur dioxide emissions.
September 1995
79
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
In addition to applying to steam generating units in general (including
wood-fueled plants), the subparts make several specific references to
wood-fueled plants. With regard to small units, the regulation
provides:
• A formula for allowable sulfur dioxide emissions (based on the
amount of fuel used) that excludes wood from the calculation of
fuel used
• Particulate matter standards for facilities that combust wood
• Opacity standards for facilities that combust wood
• Nitrogen oxide standards for facilities that combust
combinations of wood and other fuels
• Compliance procedures for facilities that combust combinations
of wood and other fuels.
Clean Water Act (CWA)
Facilities in the lumber and wood products industry that discharge
treated wastewaters from point sources to surface waters of the U.S.
must obtain a National Pollutant Discharge Elimination System
(NPDES) permit. The NPDES permit program is authorized by Section
402 of the CWA and is implemented through 40 CFR Parts 122 through
124. Other parts of the CFR affecting the NPDES program include Part
125 (technology-based standards), Part 129 (toxic pollutant standards),
and Part 130 (water quality-based standards). Discharges to publicly-
owned treatment works (POTWs) are subject to the pretreatment
standards in 40 CFR Part 403.
Technology-based permit limits are derived from effluent limitation
guidelines and standards (ELG); 40 CFR Part 429 for this industry.
These limitations incorporate both technology-based and water quality-
based limits, depending on which is more protective. Effluent
guidelines subdivide the industry based on the following production
operations:
• Veneer
• Plywood
• Dry process hardboard
• Wet process hardboard
• Wood preserving—water-borne or nonpressure
• Wood preserving—steam
• Wood preserving—Boulton.
SIC Code 24
80
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
The guidelines set limitations for the pollutants of concern (i.e., BODs,
TSS, pH, COD, phenols, and oil and grease for those facilities in the
wood preserving subcategory).
Resource Conservation and Recovery Act (RCRA)
Wood Preserving Final Rule
EPA amended regulations under RCRA (57 Federal Register 61502,
December 30, 1992) by listing as hazardous three categories of wastes
generated by wood preserving operations that use chlorophenolic,
creosote, and/or inorganic (arsenical and chromium) preservatives.
The listed wastes include wastewaters, process residuals, preservative
drippage, and spent preservatives from wood preserving processes at
facilities that use or have previously used chlorophenolic
formulations, facilities that use creosote formulations, and facilities
that use inorganic preservatives containing arsenic or chromium.
Specifically, the following RCRA-regulated hazardous wastes are
related to wood preserving operations:
• K001 (bottom sediment sludge from the treatment of
wastewaters from wood preserving processes that use creosote or
PCP),
• F032 (wastewaters, process residuals, preservative drippage, and
spent formulations from wood preserving processes generated at
plants that currently use or have previously used
chlorophenolic formulations),
• F034 (wastewaters, process residuals, preservative drippage, and
spent formulations from wood preserving processes generated at
plants that use creosote formulations), and
• F035 (wastewaters, process residuals, preservative drippage, and
spent formulations from wood preserving processes generated at
plants that use inorganic preservatives containing arsenic or
chromium).
The rule includes permitting and interim status standards for the drip
pads used to assist in the collection of treated wood drippage. These
standards include requirements for drip pad design, operation,
inspection, and closure.
September 1995
81
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), of
1947 (7 U.S.C. 136) requires registration of pesticides to protect
consumers from mislabeled, defective, and ineffective pesticides and to
identify products that might be harmful to public health or the
environment even when used properly. FIFRA has been amended
several times: in 1972, 1975, 1978, 1980, 1988, and 1991. The primary
purpose of the 1972 amendments was to ensure that pesticide use
would be subject to a thorough review of environmental and human
health hazards. The 1988 amendments established schedules and
duties for re-registration of pesticides.
Under FIFRA, a registered pesticide must be used in a manner
consistent with its label. A registered pesticide may be used in a
manner inconsistent with its label in the following situations, unless
specifically prohibited by the label:
• Applying a pesticide at a dosage, concentration, or frequency less
than that specified on the label
• Applying a pesticide against a pest not specified on the label if
the application is to a crop, animal, or site that is specified on the
label
• Employing a method of application not specifically prohibited by
the label
• Mixing a pesticide with a fertilizer
• Applying a pesticide in conformance with an experimental use
permit, or a specific exemption of a Federal or State agency
• Applying a pesticide in a manner that the Administrator
determines is consistent with the purposes of FIFRA.
Use of a registered pesticide in a manner inconsistent with its label is
unlawful in all other situations.
In addition, the Administrator has the authority to classify pesticides as
being for general use or for restricted use only. Pesticides classified as
for restricted use only include creosote, pentachlorophenol, and
inorganic salts such as chromated copper arsenate, all of which are used
in wood-preserving solutions. Such pesticides must be applied only by
a certified applicator or under the direct supervision of a certified
applicator (section 136j(a)(l)(F)). Standards for certification are
established by the Federal government or by State governments with
Federal approval.
SIC Code 24
82
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
In a notice published in the Federal Register on January 10, 1986 (Vol.
51, No. 7, January 10, 1986, p. 1334-1348), the EPA established several
conditions for registering creosote, pentachlorophenol, and inorganic
arsenicals for use in wood preserving, to ensure that such use would
not endanger human health standards. EPA and the wood preserving
industry agreed that the industry would establish a voluntary
Consumer Awareness Program to educate consumers in the proper use
of and precautionary practices regarding wood treated with creosote,
pentachlorophenol, and inorganic arsenicals, to ensure that such uses
would not endanger health standards. Through the program,
information about treated wood is disseminated in an information
sheet provided to end-users at the time of sale or delivery. An earlier
Federal Register notice of July 13, 1984 established terms of registration
under which the wood preserving industry agreed to establish air
monitoring systems at facilities using formulations containing arsenic.
VI.C. Pending and Proposed Regulatory Requirements
RCRA
As part of EPA's groundwater protection strategy, RCRA prohibits the
land disposal of most hazardous wastes until they meet a waste specific
treatment standard. While most hazardous wastes have already been
assigned treatment standards, EPA must still promulgate two
additional rule makings to address newly listed wastes and to make
changes to the land disposal restrictions (LDR) program.
When finalized, the Phase IE LDR rulemaking will establish treatment
standards for some newly listed wastes and will mandate RCRA
equivalent treatment be performed upon certain characteristically
hazardous wastes that are injected into UIC wells under the Safe
Drinking Water Act (SDWA) or managed in Subtitle D surface
impoundments prior to discharge pursuant to the Clean Water Act
(CWA). By consent decree, EPA must promulgate the final rule for
Phase III by January 1996.
Phase IV will similarly restrict other newly listed or identified wastes
from land disposal and create influent treatment standards to mitigate
the impact of sludges, leaks, and air emissions from surface
impoundments that manage decharacterized wastes. Of particular
significance to wood preserving industries. Phase IV will restrict the
land disposal of F032. F034. and P035. Once the prohibitions for these
wastes become effective, they will need to meet numeric treatment
levels for specific hazardous constituents commonly found in F032,
F034, and F035. Phase IV will also restrict the land disposal of the
previously exempt Bevill wastes and adjust the treatment standards
applicable to wastes that exhibit the toxicity characteristic for a metal
September 1995
83
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
constituent. Subject to the same consent decree, Phase IV has been
assigned a final judicial deadline of June 1996.
Clean Air Act
Many of the chemicals used for wood preserving are listed as
hazardous air pollutants (HAPs) in Section 112 of the Clean Air Act
Amendments of 1990. Treatment processes have been identified as
potentially significant sources of these HAPs and, as such, are source
categories for which national emission standards may be necessary.
Three emissions standards based on "maximum achievable control
technology" (MACT) will be developed for products covered by SIC 24:
a wood treatment MACT standard is due by November 15, 1997; a
plywood/PB manufacturing MACT standard is due by November 15,
2000; and a flat wood paneling (surface coating) MACT standard is due
by November 15, 2000. The MACT is defined as the control technology
achieving the maximum degree of reduction in the emission of the
HAPs, taking into account cost and other factors.
SIC Code 24
84
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
To date, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach
allows the Agency to track compliance with the Clean Air Act, the
Resource Conservation and Recovery Act, the Clean Water Act, and
other environmental statutes. Within the last several years, the
Agency has begun to supplement single-media compliance indicators
with facility-specific, multimedia indicators of compliance. In doing so,
EPA is in a better position to track compliance with all statutes at the
facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for
Enforcement Analysis (IDEA) system. IDEA has the capacity to "read
into" the Agency's single-media databases, extract compliance records,
and match the records to individual facilities. The IDEA system can
match Air, Water, Waste, Toxics/Pesticides/EPCRA, TRI, and
Enforcement Docket records for a given facility, and generate a list of
historical permit, inspection, and enforcement activity. IDEA also has
the capability to analyze data by geographic area and corporate holder.
As the capacity to generate multimedia compliance data improves, EPA
will make available more in-depth compliance and enforcement
information. Additionally, sector-specific measures of success for
compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation, and enforcement data from the IDEA
system, this section provides information regarding the historical
compliance and enforcement activity of this sector. In order to mirror
the facility universe reported in the Toxic Chemical Profile, the data
reported within this section consists of records only from the TRI
reporting universe. With .this decision, the selection criteria are
consistent across sectors with certain exceptions. For the sectors that do
not normally report to the TRI program, data have been provided from
EPA's Facility Indexing System (FINDS) which tracks facilities in all
media databases. Please note, in this section, EPA does not attempt to
define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within
the sector that are well defined within EPA databases.
September 1995
85
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
As a check on the relative size of the full sector universe, most
notebooks contain an estimated number of facilities within the sector
according to the Bureau of Census (See Section II). With sectors
dominated by small businesses, such as metal finishers and printers,
the reporting universe within the EPA databases may be small in
comparison to Census data. However, the group selected for inclusion
in this data analysis section should be consistent with this sector's
general make-up.
Following this introduction is a list defining each data column
presented within this section. These values represent a retrospective
summary of inspections and enforcement actions, and solely reflect
EPA, State, and local compliance assurance activities that have been
entered into EPA databases. To identify any changes in trends, the EPA
ran two data queries, one for the past five calendar years (August 10,
1990 to August 9,1995) and the other for the most recent twelve-month
period (August 10,1994 to August 9,1995). The five-year analysis gives
an average level of activity for that period for comparison to the more
recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases.
These databases do not provide data on whether inspections are
State/local or EPA-led. However, the table breaking down the universe
of violations does give the reader a crude measurement of the EPA's
and States' efforts within each media program. The presented data
illustrate the variations across regions for certain sectors.2 This
variation may be attributable to State/local data entry variations,
specific geographic concentrations, proximity to population centers,
sensitive ecosystems, highly toxic chemicals used in production, or
historical noncompliance. Hence, the exhibited data do not rank
regional performance or necessarily reflect which regions may have the
most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) ~ this system assigns a common
facility number to EPA single-media permit records. The FINDS
2 EPA Regions include the following States: I (CT, MA, ME, RI, NH, VT); II (NJ, NY PR, VI); HI
(DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (DL, IN,.MI,.UN,'OH WI); VI
CAR, LA, NM, OK, TX); VH (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI,
NV, Pacific Trust Territories); X (AK, ID, OR, WA).
SIC Code 24
86
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
identification number allows EPA to compile and review all permit,
compliance, enforcement, and pollutant release data for any given
regulated facility.
Integrated Data for Enforcement Analysis (IDEA) - is a data integration
system that can retrieve information from the major EPA program
office databases. IDEA uses the FINDS identification number to "glue
together" separate data records from EPA's databases. This is done to
create a "master list" of data records for any given facility. Some of the
data systems accessible through IDEA are: AIRS (Air Facility Indexing
and Retrieval System, Office of Air and Radiation), PCS (Permit
Compliance System, Office of Water), RCRIS (Resource Conservation
and Recovery Information System, Office of Solid Waste), NCDB
(National Compliance Data Base, Office of Prevention, Pesticides, and
Toxic Substances), CERCLIS (Comprehensive Environmental and
Liability Information System, Superfund), and TRIS (Toxic Release
Inventory System). IDEA also contains information from outside
sources such as Dun and Bradstreet and the Occupational Safety and
Health Administration (OSHA). Most data queries displayed in
notebook Sections IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search — are based on the universe of TRI reporters within
the listed SIC code range. For industries not covered under TRI
reporting requirements, the notebook uses the FINDS universe for
executing data queries. The SIC code range selected for each search is
defined by each notebook's selected SIC code coverage described in
Section II.
Facilities Inspected — indicates the level of EPA and State agency
facility inspections for the facilities in this data search. These values
show what percentage of the facility universe is inspected in a 12 or 60
month period. This column does not count non-inspectional
compliance activities such as the review of facility-reported discharge
reports.
Number of Inspections — measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections — provides an average length of
time, expressed in months, that a compliance inspection occurs at a
facility within the defined universe.
September 1995
87
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Facilities with One or More Enforcement Actions — expresses the
number of facilities that were party to at least one enforcement action
within the defined time period. This category is broken down further
into Federal and State actions. Data are obtained for administrative,
civil/judicial, and criminal enforcement actions. Administrative
actions include Notices of Violation (NOVs). A facility with multiple
enforcement actions is only counted once in this column (facility with
3 enforcement actions counts as 1). All percentages that appear are
referenced to the number of facilities inspected.
Total Enforcement Actions -- describes the total number of
enforcement actions identified for an industrial sector across all
environmental statutes. A facility with multiple enforcement actions
is counted multiple times (a facility with 3 enforcement actions counts
as 3).
State Lead Actions — shows what percentage of the total enforcement
actions are taken by State and local environmental agencies. Varying
levels of use by States of EPA data systems may limit the volume of
actions accorded State enforcement activity. Some States extensively
report enforcement activities into EPA data systems, while other States
may use their own data systems.
Federal Lead Actions — shows what percentage of the total enforcement
actions are taken by the U.S. EPA. This value includes referrals from
State agencies. Many of these actions result from coordinated or joint
State/Federal efforts.
Enforcement to Inspection Rate - expresses how often enforcement
actions result from inspections. This value is a ratio of enforcement
actions to inspections, and is presented for comparative purposes only.
This measure is a rough indicator of the relationship between
inspections and enforcement. This measure simply indicates
historically how many enforcement actions can be attributed to
inspection activity. Related inspections and enforcement actions under
the Clean Water Act (PCS), the Clean Air Act (AFS) and the Resource
Conservation and Recovery Act (RCRA) are included in this ratio.
Inspections and actions from the TSCA/FIFRA/EPCRA database are
not factored into this ratio because most of the actions taken under
these programs are not the result of facility inspections. This ratio does
not account for enforcement actions arising from non-inspection
compliance monitoring activities (e.g., self-reported water discharges)
that can result in enforcement action within the CAA, CWA and
RCRA.
SIC Code 24
88
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Facilities with One or More Violations Identified - indicates the
number and percentage of inspected facilities having a violation
identified in one of the following data categories: In Violation or
Significant Violation Status (CAA); Reportable Noncompliance,
Current Year Noncompliance, Significant Noncompliance (CWA);
Noncompliance and Significant Noncompliance (FIFRA, TSCA, and
EPCRA); Unresolved Violation and Unresolved High Priority
Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Percentages
within this column can exceed 100 percent because facilities can be in
violation status without being inspected. Violation status may be a
precursor to an enforcement action, but does not necessarily indicate
that an enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections — four
columns identify the proportion of total inspections and enforcement
actions within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA
databases. Each column is a percentage of either the "Total
Inspections," or the "Total Actions" column.
VILA. Lumber and Wood Products Industry Compliance History
Exhibit 23 provides a Regional breakdown of the five-year enforcement
and compliance activities for the lumber and wood products industry.
Region IV conducted almost 50 percent of the inspections of lumber
and wood product manufacturing facilities performed in the U.S. This
large percentage is due to the concentration of lumber and wood
product manufacturers in the Southeastern U.S. The exhibit also
indicates that 100 percent of the enforcement actions in Regions II and
VII were lead by the State while 100 percent of the enforcement actions
in Region VIII were lead by EPA.
September 1995
89
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
a
s
I
>>
i
3
13
£
•g
I
-•d
C3
S3
P&
o>
£
S-c
c2
&
c«
0)
u
Pi
c
o
U
ti
§
|
v
|
W
a;
I
^
H-t
a
0
fe
w
o
u
<
c o
B'fj o
o a*^
Us
in
a y:
si
a<
OT
"c
2 | .c
c -
|« 1 «•
3 1 gl
fl"
O (j
S
"3 c
ss-i
e I
'£* c
II
ll
oco
tS
•g
mber and W
SIC 24
o
o
1
o
en
^1-
'"
r-,
_c
OH
Ol
O
O
I
vo
~
OS
-
en
c
'1
ON
O
S
OO
oo
a
y~j
r5
§
S
(2
o
o
8
OO
OO
i
o
g
en
01
r—i
OO
Region IV
>*
o
1
ON
OS
01
3
en
en
'
jj
c
'§•
OH
-------
Sectoi Notebook Project
Lumber and "Wood Products
VII.B. Comparison of Enforcement Activity Between Selected Industries
Exhibits 24-27 contain summaries of the one and five year enforcement
and compliance activities for the lumber and wood products industry,
as well as for other selected industries. As indicated in Exhibits 24 and
25, the lumber and wood products industry has an average
enforcement to inspection rate compared to other industries. Exhibits
26 and 27 provide a breakdown of inspection and enforcement
activities by statute. Of all inspections of lumber and wood products
industry facilities, approximately 59 percent were performed under the
Resource Conservation and Recovery Act, while approximately 31
percent were conducted under the Clean Air Act. The large percentages
of RCRA and CAA inspections for this industry are due in part to
facility construction requirements for wood preserving facilities under
RCRA, and emissions standards under CAA.
September 1995
91
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
1-8
i— i
8
O
w
Q
U
»
<
II-
! J* ^
f§ o
ra J2
1^1
li
s'S
a <
c
c M
1 IM
*O [Jj
*o ta
|l'l
tt> ^ O-
bfl *3 u;
ra c ^
o c
II
3 &
21 £
II
e S
.S
i!
c
ex;
c/
j
o
o
CO
in
1
m
B
en
ON
i-H
1—1
ON
P
OO
Metal Mining
vo
0
1
VO
s
s
s
9
CO
is
CO
[Non-metallic Mineral
Mining
CM
O
t— (
fM
OS
CM
oo
t-
a
„
rt
i
i
Lumber and Wood
o
OS
OS
OS
CO
m
ro
in
"""
CO
CM
CO
a
Furniture
CM
o
CM
CM
oo
r-
a
»
O
en
vo
oo
en
en
8
in
vo
vo
Rubber and Plastic
CM
o
o
CO
1
o
CO
CO
m
in
01
oo
%
Stone, Clay, and Glass
in
o
S
VO
o
in
vo
g
cn
1
oo
Nonferrous Metals
in
o
o
01
0
oo
oo
o
oo
VO
CM
0
m
o
CO
1
Fabricated Metal
o
CM
*
CN
OO
vo
en
£
01
01
CM
in
Electronics
o
S
1
o
S
oo
vo
vo
CM
CM
S
en
oo
O\
Automobiles
en
O
*
oo
8
in
n
1—4
»n
oo
^
£
CS
in
en
(N
r-
•
-------
Sector Notebook Project
Lumber and Wood Products
•e
•M
t/5
S
•e
*-«
1
S
"3
CO
I
1
<*•»
§
I
O
ta
23
e or More
Actions
S
1
Ha
IX,
O **3
I1
Per
1
Sector
nd
Non-m
Mining
ood
al
S
s
s
5?
s
8
s
mi
Orga
s
ng
-S
•?
2
ercenes in Colu
thout a facility insp
September 1995
93
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
TJ
4)
<*-•
CJ
53
STS
^ o
PH «
0) ro
^=3
8*
S*
si
II
SIC Code 24
94
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
•M
-8
S
o
O)
•3
cc
u
.2
A
•*d
cc
o>
S
.S
H
T3
|
"£S
a.
i>
1
3 |
f2-S
S
S
58
»O
mber
cilitie
8 S
-a
a
S
S
S
s
I
El
^3
a S
Is
S-^
rt> ^
ft 5
^^?
^
tion
Co
September 1995
95
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
VH.C. Review of Major Legal Actions
VII.C.1. Review of Major Cases
This section provides summary information about major cases that
have affected this sector. As indicated in EPA's Enforcement
Accomplishments Report, FY 1991, FY 1992, FY 1993 publications, nine
significant enforcement cases were resolved between 1991 and 1993 for
the lumber and wood products industry. CAA violations comprised
four of these cases, the most of any statute. The remaining cases were
distributed fairly evenly, with CERCLA cited twice, RCRA cited twice,
and FIFRA cited once.
Three of the CAA violations involved excessive hog fuel (waste wood)
boiler emissions. Each of these settlements include Supplemental
Environmental Projects (SEPs), such as the installation of boiler
precipitators, and penalties were usually under $100,000. A notable
exception, however, is U.S. v. Louisiana-Pacific Corporation and Kirby
Forest Industries (1993). The case involved numerous violations of
State Implementation Plans, Prevention of Significant Deterioration
requirements, New Source Review requirements, and State permit
requirements at its Louisiana-Pacific facilities. The penalty assessed in
this case represents the largest CAA civil penalty ever collected by EPA,
and the second largest penalty recovered under any environmental
statute. Under the terms of a consent decree, Louisiana-Pacific was
required to pay $11.1 million in civil penalties and was required to
install state-of-the-art pollution control equipment valued at $70
million.
The remaining enforcement actions (under CERCLA, RCRA, and
FIFRA) involved sites with contamination caused by wood treatment
processes. Penalties assessed against responsible parties at these sites
ranged from $68,000 to $350,000. In addition, a CERCLA settlement at
the Koppers NPL site required Beazer East, Inc. to perform design,
construction, operation, and maintenance of an operable unit valued at
approximately $77 million.
SIC Code 24
96
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
VII.C.2. Supplemental Environmental Projects (SEPs)
Supplementary Environmental Projects (SEPs) are compliance
agreements that reduce a facility's stipulated penalty in return for an
environmental project that exceeds the value of the reduction. Often,
these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
In December, 1993, the Regions were asked by EPA's Office of
Enforcement to provide information on the number and type of SEPs
entered into by the Regions. Exhibit 28 contains a representative
sample of the Regional responses addressing the lumber and wood
products industry. The information contained in the chart is not
comprehensive and provides only a sample of the types of SEPs
developed for the lumber and wood products industry.
September 1995
97
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
£
U
CU
•ET
la
.•t! o 'S
3.s §
|wl
3-i
s §
I— 1
OH
CO
Is c
C 0
p« H5
^ n bC
13 w •-
I$S
-V.
Tn to "e3
.S <§ 5
PH < PH
Expected Environmental
Benefits
"g ^
| 5 |
S *• 5
£s<5
Type of SEP
(U *1 t
^ o c!
ill
if
0)
CO
n
U
oo
CO*
S
CN|
CJ\
N
aJ
iO
Installation of electrified
bed to reduce particulate
emissions.
o
S
£
rH
«3-
Pollution
Reduction
HH
op
^^
^^
U
o
» Louisiana-Pacific
Corporation
Movie Springs, ID
3
r- i
00
I>
c^
CJ
Installation of electrostati
precipitator to reduce
particualte emissions.
^
»
CO"
»
Pollution
Reduction
00
U
o
t-H
Merritt Brothers Lumber
Company
Priest River, ID
S
*«o
00
I— 1
o
o
t^
pa
U
PH
Early disposal of PCB and
contaminated electrical
equipment.
CO
CN
tC
CO
Pollution
Reduction
U
o
vH
Rosboro Lumber
Company
Springfield, OR
o
m
t^
oo'
o
o
"I
—i
^
Purchase and installation
"hog" machine to reduce
particulate emissions.
g
06*
in
Pollution
Prevention
i
3
0
r-l
IjD Lumber, Inc.
Priest River, ID
o
rH
0
O
°,
S
'o o a
Purchase and installation
electrostatic precipitator 1
reduce particulate emissio
0
o
S
Pollution
Reduction
S
U
o
rH
Riley Creek Lumber
Company
Laclede, ID
0
<— '
<— ^
m
o
'-J.
c-l
O *\i O [ QJ
^ -a g *
Donate emergency and/or
computer equipment to the
Emergency Planning Comr
(LEPC) to respond to and/
for chemical emergencies.
Participate in LEPC activ
o
o
o
w-
S C
£••§
||
3
U
vo
_o
'd
-------
Sector Notebook. Project
Lumber and Wood Products
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector
and public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also contains
a listing and description of national and regional trade associations.
VIII.A. Sector-Related Environmental Programs and Initiatives
EPA Region X conducted the "Idaho Rule Effectiveness Study" from
March 1991 through October 1992 in the Idaho Panhandle. The study
focused on sources of PM and was designed to evaluate the
effectiveness of Idaho rules regulating particulate emissions: the
sources selected for the study, which included many wood products
facilities, were located in or near suspected PM10 non-attainment areas.
Inspections evaluated the compliance status of 26 sources with respect
to Idaho rules concerning emissions limitations, visible emissions
limitations for wigwam burners, permits to construct, operating
permits, and particulate standards for combustion sources.
EPA's impression following completion of the study was that existing
controls were not adequate to comply with applicable regulations. A
majority of sources used multiclones as their primary control device.
Equipment was not routinely maintained; sources did not appear to
have a routine operation and maintenance program (O&M); and many
mill managers had little knowledge of the air quality regulations that
applied to their facility.
A second conclusion reached by EPA was that environmental
responsibilities were secondary to those related to the operation of the
mill. Even at the largest facilities, the manager of the mill was also
responsible for environmental compliance and reported to a
production-oriented management structure.
The study resulted in the following actions and lessons learned:
• Five facilities installed air pollution control equipment that will
permanently reduce PM10 emissions by 415 tons/year. These
installations were in response to enforcement actions issued by
the Region during the study. Two additional facilities
eliminated wood waste incineration entirely, reducing PM10
emissions by over 250 tons/year;
September 1995
99
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
VHI.B.
General industry awareness of environmental regulations has
been improved substantially as a result of the initiated
inspections, subsequent enforcement actions, and meetings with
EPA;
It is important for a regulatory agency to conduct unannounced
inspections;
After meeting with EPA, an industry group sponsored an opacity
certification school in October 1991 which was attended by
numerous industry representatives. Additional certifications
have been held each April and October since then;
The problem of wood waste disposal is not only an air quality
problem. Resolution of the enforcement cases developed in this
study showed that recognition should be given to multimedia
environmental impacts;
Most of the sources will need to obtain operating permits.
EPA Voluntary Programs
33/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic
chemical releases and transfers of 17 chemicals from manufacturing
facilities. Participating companies pledge to reduce their toxic chemical
releases and transfers by 33 percent as of 1992 and by 50 percent as of
1995 from the 1988 baseline year. Certificates of Appreciation have
been given to participants who met their 1992 goals. The list of
chemicals includes 17 high-use chemicals reported in the Toxics
Release Inventory.
Twenty-four companies and 43 facilities listed under SIC 24 (lumber
and wood products) are currently participating in the 33/50 program.
They account for approximately nine percent of the 491 companies
under SIC 24. This is lower than the average for all industries of 14
percent participation. (Contact: Mike Burns 202-260-6394 or the 33/50
Program 202-260-6907)
SIC Code 24
100
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Exhibit 29 lists those companies participating in the 33/50 program that
reported under SIC code 24 to TRI. Many of the participating
companies listed multiple SIC codes (in no particular order), and are
therefore likely to conduct operations in addition to Lumber and Wood
Products manufacturing. The table shows the number of facilities
within each company that are participating in the 33/50 program; each
company's total 1993 releases and transfers of 33/50 chemicals; and the
percent reduction in these chemicals since 1988.
Exhibit 29
Lumber and Wood Facilities Participating in the 33/50 Program
Parent Facility Name
Blue Circle America Inc
C. M. Tucker Lumber Corp.
Elco Forest Products Inc
Flagship Trading Corp
Georgia-Pacific Corporation
Hagerwood Inc
Honolulu Wood Treating Co.
Hutchens Industries Inc
International Paper Company
Julian Lumber Co Inc
Louisiana-Pacific Corporation
Mascotech
Potlatch Corporation
Premark International Inc
R L C Industries Co
States Industries Inc
Tarkett North Amercn
foldings
Taylor-Ramsey Corporation
Thrift Brothers Lumber Co Inc
Tri-State Pole & Piling Inc
Union Camp Corporation
Weyerhaeuser Company
Willamette Industries Inc
Wood Preservers Inc
Parent City
Marietta
Pageland
Opelousas
Cleveland
Atlanta
Grand Rapids
Ewa Beach
Springfield
Purchase
Antlers
Portland
Taylor
San Francisco
Deerfield
Dillard
Eugene
Parsippany
Madison Heights
Westminster
Lucedale
Wayne
Tacoma
Portland
Warsaw
ST
GA
SC
LA
OH
GA
MI
ffl
MO
NY
OK
OR
MI
CA
IL
OR
OR
NJ
VA
SC
MS
NJ
WA
OR
VA
SIC
Codes
2491
2491
2491
2491
2493
2491
2491
3799,
3325, 2421
2435
2491
2421, 2435
2426
2431, 2426
2436
2435, 2436
2435
2426
2491
2491
2491
2611,
2621,2631
2491
2493
2491
# of
Participating
Facilities
1
2
1
1
3
2
1
1
5
1
5
1
2
3
1
1
1
1
1
1
1
5
1
1
1993
Releases am
Transfers
(Ibs.)
250
1,000
0
250
2,722,182
1,000
256
298,000
2,784,831
250
294,823
3,163,830
276,643
140,313
129,083
16,272
30,190
255
510
71,255
835,696
1,006,356
677,090
31
%
Reduction
1988 to
1993
*
*
75
***
50
*
50
68
50
50
50
35
60
***
48
50
35
***
*
*
50
*
34
50
* - not quantifiable against 1988
ata.
** = use reduction goal only.
*** = no numerical goal.
September 1995
101
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national initiative
piloted by EPA and State agencies in which facilities have volunteered
to demonstrate innovative approaches to environmental management
and compliance. EPA has selected 12 pilot projects at industrial
facilities and Federal installations which will demonstrate the
principles of the ELP program. These principles include:
environmental management systems, multimedia compliance
assurance, third-party verification of compliance, public measures of
accountability, community involvement, and mentoring programs. In
return for participating, pilot participants receive public recognition
and are given a period of time to correct any violations discovered
during these experimental projects. (Contact: Tai-ming Chang, ELP
Director, 202-564-5081 or Robert Fentress, 202-564-7023)
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek
to achieve cost effective environmental benefits by allowing
participants to replace or modify existing regulatory requirements on
the condition that they produce greater environmental benefits. EPA
and program participants will negotiate and sign a Final Project
Agreement, detailing specific objectives that the regulated entity shall
satisfy. In exchange, EPA will allow the participant a certain degree of
regulatory flexibility and may seek changes in underlying regulations
or statutes. Participants are encouraged to seek stakeholder support
from local governments, businesses, and environmental groups. EPA
hopes to implement fifty pilot projects in four categories including
facilities, sectors, communities, and government agencies regulated by
EPA. Applications will be accepted on a rolling basis and projects will
move to implementation within six months of their selection. For
additional information regarding XL Projects, including application
procedures and criteria, see the May 23,1995 Federal Register Notice, or
contact Jon Kessler at EPA's Office of Policy Analysis (202) 260-4034.
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-
efficient lighting technologies. The program has over 1,500 participants
which include major corporations; small and medium sized
businesses; Federal, State and local governments; non-profit groups;
schools; universities; and health care facilities. Each participant is
SIC Code 24
102
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
required to survey their facilities and upgrade lighting wherever it is
profitable. EPA provides technical assistance to the participants
through a decision support software package, workshops and manuals,
and a financing registry. EPA's Office of Air and Radiation is
responsible for operating the Green Lights Program. (Contact: Susan
Bullard at 202-233-9065 or the Green Light/Energy Star Hotline at 202-
775-6650)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid
Waste and Emergency Response. The program is aimed at reducing
municipal solid wastes by promoting waste minimization, recycling
collection, and the manufacturing and purchase of recycled products.
As of 1994, the program had about 300 companies as members,
including a number of major corporations. Members agree to identify
and implement actions to reduce their solid wastes and must provide
EPA with their waste reduction goals along with yearly progress
reports. EPA in turn provides technical assistance to member
companies and allows the use of the WasteWi$e logo for promotional
purposes. (Contact: Lynda Wynn, 202-260-0700 or the WasteWi$e
Hotline at 1-800-372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the U.S.
commitment to reduce greenhouse gas emissions in accordance with
the Climate Change Convention of the 1990 Earth Summit. As part of
the Climate Change Action Plan, the Climate Wise Recognition
Program is a partnership initiative run jointly by EPA and the
Department of Energy. The program is designed to reduce greenhouse
gas emissions by encouraging reductions across all sectors of the
economy, encouraging participation in the full range of Climate
Change Action Plan initiatives, and fostering innovation. Participants
in the program are required to identify and commit to actions that
reduce greenhouse gas emissions. The program, in turn, gives
organizations early recognition for their reduction commitments;
provides technical assistance through consulting services, workshops,
and guides; and provides access to the program's centralized
information system. At EPA, the program is operated by the Air and
Energy Policy Division within the Office of Policy Planning and
Evaluation. (Contact: Pamela Herman, 202-260-4407)
September 1995
103
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
NICE3
The U.S. Department of Energy and EPA's Office of Pollution
Prevention are jointly administering a grant program called The
National Industrial Competitiveness through Energy, Environment,
and Economics (NICE3). By providing grants of up to 50 percent of the
total project cost, the program encourages industry to reduce industrial
waste at its source and become more energy-efficient and cost-
competitive through waste minimization efforts. Grants are used by
industry to design, test, demonstrate, and assess the feasibility of new
processes and/or equipment with the potential to reduce pollution and
increase energy efficiency. The program is open to all industries;
however, priority is given to proposals from participants in the pulp
and paper, chemicals, primary metals, and petroleum and coal products
sectors. (Contact: DOE's Golden Field Office, 303-275-4729)
VIILC. Trade Association/Industry Sponsored Activity
VHLC.l. Environmental Programs
A consortium of Universities, DOE National Laboratories, Forest
Service Researchers, and Industrial partners have submitted a
coordinated package of proposals for funding under EPA's
"Environmental Technology Initiative" (ETI) program aimed at
reducing pollution in wood products production. A total of five
proposals were submitted, including: "Diffusion of Pollution
Prevention Technology for the Lumber and Wood Products Industry,"
"Process Control Technology to Mitigate VOC Air Emissions in the
Production of Oriented Strand Board," "Improved Wood Adhesives
for Reduction of Pollutants for the Wood Panel Manufacturing
Industry," "Identification and Quantification of Volatile Organic
Compounds Emitted from Lumber Dry Kilns," and "Development of
Coupled Biological/Chemical Systems to Reduce VOCs in Lumber and
Composite Board Facilities." These projects are currently underway at
the Forest Products Laboratory in Madison, Wisconsin.
To explore questions related to potential technologies which might be
applicable for control of wood panel plant VOC emissions, the
American Forest & Paper Association (AF&PA) Solid Wood
Committee and NCASI hosted a workshop in October 1993. It was
attended by approximately 100 individuals from industry, State
regulatory agencies, EPA, and EPA consultants. At the workshop, the
following five control technologies were discussed: ultraviolet
oxidation, chemical scrubbing with brominated compounds, furnish
dryer exhaust gas recirculation to a wood-fired fuel cell for oxidation of
SIC Code 24
104
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
VIII.C.2.
organic compounds, biofiltration, and regenerative thermal oxidation.
Topics discussed included: current status of development,
performance, problems encountered, potential limitations, energy
requirements, and estimated costs. In addition, an EPA representative
updated the workshop attendees on the Agency's current efforts to
develop a common definition of VOCs and to adopt a standard VOC
test method for emissions from solid wood manufacturing plants.
According to the American Forest and Paper Association, wood
recycling is on the rise. An estimated 400,000 tons of wood waste were
recovered in 1990. This waste included barrels, boxes, brush, Christmas
trees, construction and demolition waste, crates, pallets, posts, poles,
prunings, railroad ties, sawdust, slab wood, and yard trimmings. The
management of wood residue as a component of construction and
demolition waste and from urban tree removals is becoming a larger
issue as landfill tipping fees rise. Wood residue management is also an
increasingly important issue for wood products producers, retailers,
and the general public. As virgin wood fiber prices rise, incentives and
cost-avoidance pressures are motivating wood users and producers to
find ways to fully and most profitably utilize this resource.
The American Forest and:,Paper Association's American Wood Council
is producing a Wood Recycling Reference Handbook to encourage and
facilitate wood recycling in the United States. The book will list by state
and county where wood residue can be bought for reuse and recycling.
The first edition is due out in October, 1995.
Summary of Trade Associations
There are numerous trade and professional organizations affiliated
with the forest products industry. The largest organization is the
American Forest and Paper Association. The smaller associations
generally focus on specific types of timber (i.e., hardwoods, pine), or
specific types of product (i.e., plywood, particleboard). In addition, there
are a number of trade organizations which focus their efforts on
specific regions of the country.
September 1995
105
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
General
Hardwood
American Forest and Paper Association
111119th Street, NW, Suite 800
Washington, DC 20036
Phone: (202)463-2700
Fax: (202) 463-2785
Members: 425
Contact: Josephine Cooper
The American Forest and Paper Association (AF&PA) is the national
trade association of the forest, pulp, paper, paperboard, and wood
products industry. AF&PA represents approximately 500 member
companies and related trade associations (whose memberships are in
the thousands) which grow, harvest, and process wood and wood fiber;
manufacture pulp, paper and paperboard products from both virgin
and recovered fiber; and produce solid wood products.
National Council of the Paper Industry for Air
and Stream Improvement
260 Madison Avenue
New York, NY 10016
Phone: (212)532-9000
Fax: (212)779-2849
Members: 100
Staff: 90
Budget: $10,000,000
Contact: Dr. Ronald Yeske,
President
Founded in 1943, the National Council of the Paper Industry for Air
and Stream Improvement (NCASI) presently conducts research on
environmental problems related to industrial forestry and the
manufacture of pulp, paper, and wood products. NCASI produces
technical documents on environmental issues facing the pulp and
paper industry and conducts industry conferences. Publications
include: a biweekly bulletin on general issues and a variety of technical
bulletins (40/year). NCASI also holds and annual March convention
in New York City.
Hardwood Manufactures Association
400 Perm Center Blvd.
Pittsburgh, PA 15235
Phone:(412)346-2222
Fax: (412) 346-2233
Members: 145
Staff: 5
Contact: Susan Regan
Manufacturers of hardwood lumber and hardwood products. Conducts
promotion programs; compiles statistics.
SIC Code 24
106
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Plywood
National Hardwood Lumber Association
PO Box 34518
Memphis, TN 38184-0518
Phone: (901)377-1818
Fax: (901)382-6419
Members: 1300
Staff: 40
Contact: Ernest J. Stebbins
United States and Canadian hardwood lumber and veneer
manufacturers, distributors, and consumers. Inspects, measures, and
certifies hardwood lumber. Maintains inspection training school and
conducts short courses at members' lumber yards; conducts
management and marketing seminars for the hardwood industry. The
organization publishes the National Hardwood Lumber Association-
Annual Report and the National Hardwood News, an annual
newsletter.
Hardwood Plywood & Veneer Association
1825 Michael Faraday Dr.
PO Box 2789
Reston, VA 22090
Phone: (703) 435-2537
Members: 150
Staff: 12
Budget: $1,000,000
Contact: E.T. Altaian
Manufactures and prefinishers of hardwood plywood; manufacturers
of veneer; suppliers of glue, machinery, and other products related to
the industry. Conducts laboratory testing of plywood, adhesives,
finishes, flamespread, formaldehyde emissions, structural, and smoke
density. The association provides public relations, advertising,
marketing, and technical services to members. It represents the
industry in legislative matters and keep members informed on tariff
and trade actions. Publications include the annual Hardwood Plywood
and Veneer News and The Executive Brief.
American Plywood Association
PO Box 11700
Tacoma, WA 98411
Phone: (206) 565-6600
Fax: (206) 565-7265
Members: 136
Staff: 180
Budget: $14,000,000
Contact: Gene Zellner
Manufacturers of plywood, oriented strand board and composites.
Conducts trade promotion through advertising, publicity,
merchandising, and field promotion. The Association provides quality
oversight and conducts research to improve products, applications, and
manufacturing techniques. Publications include the Management
Report, and periodic Plywood Statistics.
September 1995
107
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Hardboard
American Hardboard Association
1210 W. Northwest Highway
Palatine, IL 60067
Phone: (708) 934-8800
Fax: (708) 934-8803
Members: 4
Staff:
Budget:
Contact: C. Curtis Peterson
Manufacturers representing major U.S. producers of hardboard.
Particleboard
National Particleboard Association
18928 Premiere Court
Gaithersburg, MD 20879
Phone: (301) 670-0604
Fax: (301) 840-1252
Members: 19
Staff: 10
Budget:
Contact: Richard Margosian
Mat-formed wood particleboard and medium-density fiberboard
manufacturers interested in establishing industry product standards
with the American National Standards Institute and quality standards
for performance. Sponsors educational programs and publishes
promotional and technical bulletins on topics including laminating
and veneering.
Wood Preserving
American Wood-Preservers' Association
P.O. Box 286
Woodstock, MD 21163-0286
Phone: (410)465-3169
Fax: (410)465-3195
Members: 2000
Staff:
Budget:
Contact: John F. Hall
The association includes processors and users of chemically treated
wood and is affiliated with the American Wood Preservers Institute.
Publications include the annual AWPA Book of Standards, which is a
technical handbook covering preservatives and treatments.
SIC Code 24
108
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Regional
American Wood Preservers Institute
1945 Old Gallows Road, Ste. 150
Vienna, VA 22182-3931
Phone: (703) 893-4005
Fax: (703) 893-8492
Members: 150
Staff: 8
Budget: $1,100,000
Contact: Gene Bartlow
The American Wood Preservers Institute is the national trade
association representing the wood preserving industry. Its members
include manufacturers of treated wood products, manufacturers and
distributors of wood preservatives, and providers of allied services.
AWPI provides technical forums for the industry, publishes a bi-
monthly newsletter, and produces annual Industry Statistical Reports.
Northeastern Lumber Manufacturers
Association
272 Turtle Rd., Box 87A
Cumberland Center, ME 04021
Phone: (207) 829-6901
Fax: (207) 829-4293
Members: 200
Staff: 7
Budget:
Contact: Stephen Clark
Northeastern Lumber Manufacturers is an association of hardwood
and softwood lumber and timber products manufacturers in New
England. The group promotes the interests of the Northeastern
lumber manufacturing industry and presents the views of the industry
to other organizations, the government, and the public. Publications
include the monthly Northeastern Lumber Manufacturers Association.
Southeastern Lumber Manufacturers
Association
PO Box 1788
Forest Park, GA 30051
Phone: (404) 361-1445
Fax: (404) 361-5963
Members: 390
Staff: 10
Budget: $2,000,000
Contact: Ed C. Cone, Jr.
Represents Southeastern hardwood and softwood lumber
manufacturers and coordinates efforts of membership to alleviate local,
regional, and national problems that affect the regional lumber
industry. Publishes a quarterly newsletter, Silva Magazine, and
Management Update. SLMA also conducts technical workshops.
September 1995
109
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Southern Forest Products Association
PO Box 52468
New Orleans, LA 70152
Phone: (504)443-4464
Fax: (504)443-6612
Members: 220
Staff: 31
Budget: $2,856,000
Contact: Karl Lindberg
The Southern Forest Products Association (SFPA) represents Southern
pine lumber manufacturers and conducts market development and
product promotional programs and government support activities.
SFPA publishes a weekly newsletter covering a variety of industry
activities.
Western Wood Preservers Institute
601 Main Street, Suite 405
Vancouver, WA 98660
Phone: (360)693-9958
Fax: (360)693-9958
Members: 50
Staff: 3
Budget:
Contact: Dennis Hayward
WWPI represents the treated wood industry in Western North
America. WWPI provides educational information to assist
consumers in the selection and proper, safe, and environmentally
appropriate use of treated wood products.
Western Wood Products Association
Yeon Building
522 SW 5th Ave.
Portland, OR 97204-2122
Phone: (503)224-3930
Fax: (503)224-3934
Members: 250
Staff: 63
Budget:
Contact: Robert Hunt
WWPA is a rules-writing agency (for lumber grades), approved under
the American Lumber Standard Committee under the jurisdiction of
the Department of Commerce. The Association also provides
economic and statistical information on the Western lumber industry,
conducts research in wood technology, engineering and performance;
provides technical and educational services both domestically and
internationally; and published technical and consumer information for
Western Lumber end-use.
SIC Code 24
110
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
ix. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
General Profile
Compilation of Air Pollutant Emissions Factors (AP-42), U.S. EPA.
Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc.,
Detroit, Michigan, 1992.
Price Prospects for Major Primary Commodities, 1990-2005, The World Bank,
March, 1993.
Standard Industrial Classification Manual, Office of Management and Budget, 1987.
Sustainable Environmental Law, Campbell-Mohn, Environmental Law Institute,
1993.
U.S. Industrial Outlook 1994, Department of Commerce.
Wood Preserving, U.S. EPA (EPA/530-SW-90-027f).
Wood Products Industry Associations, American Forest and Paper Association,
Washington, D.C., January, 1994.
1987 Census of Manufacturers Industry Series 24A: Logging, Camps Sawmills, &
Planing Mills, U.S. Department of Commerce, Bureau of the Census, April 1990
(MC87-I-24A).
1987 Census of Manufacturers Industry Series 24B: Millwork, Plywood, & Structural
Materials, U.S. Department of Commerce, Bureau of the Census, April 1990 (MC87-I-
24 A).
1987 Census of Manufacturers Industry Series 24C: Wooden Containers &
Miscellaneous Wood Products, U.S. Department of Commerce, Bureau of the
Census, April 1990 (MC87-I-24A).
1992 Census of Manufacturers, Industry Series 24-A: Logging Camps ,Sawmills, and
Planing Mills, U.S. Department of Commerce, Bureau of the Census, February 1995
(MC92-I-24C).
1992 Census of Manufacturers Industry Series 24B: Millwork, Plywood, and
structural Wood Members, Not Elsewhere Classified, Bureau of the Census,
February 1995 (MC92-I-24B)
September 1995
111
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
1992 Census of Manufactures Industry Series 24C: Wooden Containers and
Miscellaneous Wood Products, February 1995 (MA2-I-24C).
Process Descriptions
Basic Plywood Processing, Ted Demas, American Plywood Association, Tacoma,
Washington, December, 1992.
Characterization of Manufacturing Processes, Emissions, and Pollution Prevention
Options for the Composite Wood Industry, Cybele Martin and Coleen Northeim,
Research Triangle Institute Center for Environmental Analysis, RTF, NC, March
1995.
Encyclopedia of Science and Technology, Wood Finishing (vol. 19), Lumber
Manufacture (vol. 10), Logging (vol. 10), 1992.
Estimating Chemical Releases from Presswood and Laminated Wood Products
Manufacturing, U.S. EPA, Office of Pesticides and Toxic Substances, March 1988 (EPA
560/4-88-0041).
Forest Products and Wood Science, An Introduction, John G. Haygreen and Jim L.
Bowyer, Iowa State University Press, 1989.
Investigation of Emissions from Plywood Veneer Dryers, Appendix B, Plywood
Research Foundation, March 1971.
Modern Particleboard & Dry-Process Fiberboard Manufacturing, Thomas M.
Maloney, Miller Freemen, Inc., San Francisco, CA, 1993.
Study of the Physical and Chemical Properties of Atmospheric Aerosols Attributable
to Plywood Veneer Dryer Emissions, Chemical Engineering Department,
Washington State University, June 1981.
Wood Products for Engineered Structures: Issues Affecting Growth and Acceptance
of Engineered Wood Products, Donald A. Bender, Ed., Forest Products Society,
Madison, Wisconsin, November 1992.
Release Profiles
Enforcement Accomplishments Report, FY 1991, U.S. EPA, Office of Enforcement
(EPA/300-R92-008), April 1992.
Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement
(EPA/230-R93-001), April 1993.
SIC Code 24
112
September 1995
-------
Sector Notebook Project
Lumber and Wood Products
Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement
(EPA/300-R94-003), April 1994.
Final Modifications to the Wood Preserving Regulations, Environmental Fact
Sheet, Office of Solid Waste, U.S. EPA, October, 1992 (EPA/530-F-92-029).
Surface Protection Proposed Rule, 58 Federal Register 25706, April 27, 1993.
Unified Agenda, 57 Federal Register 21120, April 1994.
Wood Preserving Final Rule, 57 Federal Register 61502, December 30, 1992.
September 1995
113
SIC Code 24
-------
Lumber and Wood Products
Sector Notebook Project
Pollution Prevention
Guides to Pollution Prevention: Wood Preserving Industry, U.S. EPA, Office of
Research and Development, November 1993 (EPA/625/R-93/014).
Pollution Prevention 1991: Progress on Reducing Industrial Pollutants, Office of
Pollution Prevention, U.S. EPA, 1991 (EPA 21P-3003).
Waste Minimization Practices at Two CCA Wood-Treatment Plants, U.S. EPA,
Office of Research and Development, August 1993 (EPA/600/R-93/168).
Contacts*
Name
Michael Caldwell
Albert Lukban
Buddy Perry
Nicholas Latham
Jim Yuhas
Bill Wyndes
Mark Rivas
Chris James
Maria Dixon
Kurt Bigbee
John Pinkerton
Organization
American Forest and Paper
American Wood Preservers Institute
Perry Builders
Natural Resources Defense Council
Western Wood Products
Louisiana-Pacific
U.S. EPA, Region VII (inspector)
U.S. EPA, Region X (inspector)
U.S. Bureau of the Census
American Plywood Association
NCASI
Telephone
202-463-2762
703-893-4005
919-492-9171
202-624-9363
503-224-3930
707-443-7511
913-551-7669
206-553-1194
301-763-5895
202-565-6600
212-532-9047
* Many of the contacts listed above have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals listed do not
necessarily endorse all statements made within this notebook.
SIC Code 24
114
September 1995
-------
APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIROSENSE WORLD WIDE WEB
To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
Web Browser to the following address:
http://eS.inel.gOV/OeCa - then select "EPA Sector Notebooks"
Of after 1997, (when EPA plans to have completed a restructuring of its web site) set
your web browser to the following address:
WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
Sectors and select the appropriate sector from the menu.
The Notebook will be listed.
HOTLINE NUMBER FOR E$WWW: 208-526-6956
EPA E$WWW MANAGERS: Louis Paley 202-564-2613
Myles Morse 202-260-3151
(This page updated June 1997)
Appendix A
-------
-------
United States Government
INFORMATION
PUBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
Charge your order.
It's easy!
(MotferCord
Order Processing Code:
* 3212
Fax your orders (202) 512-2250
Phone your orders (202) 512-1800
V j&S&^Of-' **^^*V>,,?S^^^U»S1,- * x »«=tK*«v „
Qty.
Stock Number
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
Published in 1995 Title
Dry Cleaning Industry, 104 pages
Electronics and Computer Industry, 1 60 pages
Fabricated Metal Products Industry, 1 64 pages
Inorganic Chemical Industry, 136 pages
Iron and Steel Industry, 1 28 pages
Lumber and Wood Products Industry, 1 36 pages
Metal Mining Industry, 148 pages
Motor Vehicle Assembly Industry, 1 56 pages
Nonferrous Metals Industry, 140 pages
Non-Fuel, Non-Metal Mining Industry, 1 08 pages
Organic Chemical Industry, 152 pages
Petroleum Refining Industry, 1 60 pages
Printing Industry, 1 24 pages
Pulp and Paper Industry, 1 56 pages
Rubber and Plastic Industry, 152 pages
Stone, Clay, Glass and Concrete Industry, 1 24 pages
Transportation Eguipment Cleaning Industry, 84 pages
Wood Furniture and Fixtures Industry. 132 paces
Price
Each
$ 6.50
11.00
11.00
9.00
8.00
9.00
10.00
11.00
9.00
6.50
11.00
11.00
7.50
11.00
11.00
7.50
5.50
8.00
Total |
Price 1
r
f
i
$
i
£
i
s
a1
^
i
1
^
1
K
^
p
«^*Ss5®5^ss^2K'^jlL4^^
Qty.
Stock Number
055-000-00570-2
055-000-00571-1
055-000-00572-9
055-000-00573-7
055-000-00574-5
055-000-00575-3
055-000-00576-1
055-000-00577-0
055-000-00578-8
055-000-00579-6
Published in 1997 Title
Air Transportation Industry, 90 pages
Ground Transportation Industry, 130 pages
Water Transportation Industry, 90 pages
Metal Casting Industry, 1 50 pages
Pharmaceutical Manufacturing industry, 1 47 pages
Plastic Resin & Man-made Fiber industry, 180 pages
Fossil Fuel Electric Power Generation Industry, 160 pages
Shipbuilding and Repair Industry, 1 20 pages
Textile Industry, 130 pages
Sector Notebook Data Refresh -1997, 210 pages
Price
Each
$ 7.50
10.00
7.50
13.00
13.00
15.00
14.00
9.50
10.00
17.00
Total for Publications
Total |
Price 1
i|
1
I
|
1
l|
1
1
1
1
1
The total cost of my order is
_.. Price includes regular shipping and handling and is subject to change.
Company or personal name
(Please type or print)
Additional address/attention line
Check method of payment:
Q Check payable to Superintendent of Documents
Q GPO Deposit Account I I I I I || |-|~1
QVISA Q MasterCard Q Discover/NOVUB
Street address
City, State, Zip code .
(expiration date) Thank you for your order!
Daytime phone including area code
7/97
Authorizing signature
Mail to: Superintendent of Documents
P.O. Box 371954, Pittsburgh, PA 15250-7954
Purchase order number (optional)
Important: Please include this completed order form with your remittance.
-------
-------
|