### Air Quality Data and Observations Made in Vermont during the November 2006 Trial

Burn of Tire Derived F u el at the Intern ational Paper Company, Ticonderoga, Ne w York

Final Report January 2008

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Page 2 of 42

## Table of Contents

Executive Summary

........................................................................................................ 5

Overview of Events Pr ec eding the Tr ial Burn

.................................................................. 7

On-site Tri a l Burn Ob servation Summari es

..................................................................... 9

Ambient Air Monitoring

.................................................................................................. 12

In troduc ti on

.............................................................................................................. 12

Vermon t ANR Intensive Sampling

............................................................................ 12

Contrac t ed Privat e Research Gr oup Samp ling

........................................................ 15

Appendices

Appendix I – Trial Burn Field Obs e rvations/Site Reports

Appendix II -- Summary of Meteorolog ical Analysis & Air Quality Modeling

Appendix III -- Summa ry Analysis of Transport Wind Fields

Page 3 of 42

### [Blank Page]

Page 4 of 42Executive Summary

In Septemb e r of 2003 t he International Paper Compan y (I P) submitted a request to the State of

New York Department o f Environ m e n tal Conser vation (NYDEC) for app roval to conduct a trial
burn of tire fuel in their Power boiler. IP propo sed to burn shredded tires, referred to as tirederived-fuel (TDF), at a rate of up to 3 tons per hour; which is approximately 10% of the heat input capacity of the 855 million BTU per hour Power boiler. Th e Power b o iler burns predominantly No.6 fuel oil but al so has sol i d fuel burni ng capabilit y. IP typic a lly burns wood/bark at a rate of 425 tons per day which is approxima t ely 20% of the boiler capacity. IP proposed to maintain th e wood/bark firing at a constant rate and mix in increasing a m ounts of
TDF as No.6 fuel oil was to be de cr eased prop ortionately. TDF use at the facility was intended to displa ce No.6 fuel oil usage and l o wer the mill's energy co sts.

The State of Vermont formally raised concerns and objectio n s with IP a nd the NYDEC with the proposal ba sed on the belief that t he Power boiler was no t fitted with appropriate exhaust gas clean-up te chnology to properly control the effluent from burring tire -derived fuel. However, seeing that there was a likelihoo d that the project would be mo ving forward, the Vermont Agency of Natural Reso urces, Depa rtment of Environmental Conservation, Air Pollut i on Control Division (APCD) was tasked with conducting ambient air quality monitoring to det ermine IP’s impact on Vermont in the event the trial proce eded. Identifying and isolating IP’s impact on ambient air quality in Vermont from all other so urces of air contaminants was expected to be
difficult given the likely small impacts attributab le to the p l ant compared to existing ambient

levels. The general net work design thought be st to accomplish th is go al was to lo cate two air quality monitoring sites in the vicinity of the plant; one “upwind” and one “downwind” of the plant. To this end, two nearly i dentical monitoring stations were established, o ne northeast of the plant and one southeast of the plant, both in the t o wn of Sho r eham and approximate l y 2.5 miles distant from the plant. The location s were sele cted based on modeling of the most likely and significant a r eas of imp a ct. Assuming IP’s emission p l ume would only impact one monitoring station simultaneously, the difference between t he ambient l e vels at the two stations when IP’s plume was impacting one could be inferred to be due to a lo cal source such as IP.

The two mo nitoring stations began collecting sa mples in late 2003. The monitoring consisted o f every six d a y sampling (24 hour s a mples) for particulate matter less than 10 mic r ons in size (PM 10 ) and fine particula te matter less than 2.5 microns in size (PM 2.5 ). T D F combustion is most

associat ed with an incr ease in fine particulat e matter due to the prese n ce of zinc oxide in the

tires themse lves that for m s fine particles when b u rned and t herefore was expected t o be difficult to control with the existing emissio n control dev ices in place at IP. These early monitoring samples prior to the tria l burn would provide a b a ckground level on whi c h to compa r e readings during the trial. Differences in the readings at the two stations could also indicat e an impact

associat ed with IP’s cur r ent operations without TDF. While there were several inst ances wher e the two mo nitors detect ed slight diff erences in ambient levels prior to t he trial burn

, it was not possible to definitively determine t he reason or identify th e source of the difference as being related to IP operations.

Two weeks prior to th e trial burn that began on November 6, 2006 the APCD ramped up monitoring efforts, incr easing particulate samp ling to ever y day. To supplement and enhance
the APCD a i r quality measurements during the trial, the APCD contra cted with th ree external research gr oups to co nduct additional air qu ality monitoring. This supplemental monitoring included: ga seous elemental, reactive gaseous and particulate mercury at the Shoreham Nort h site; continu ous hourly measureme n ts of PM 2.5 mas s by F D MS TEO M , SO 2 gas, SO 4 aerosol, organic car bon, elemental carbon, polycyclic aromatic hydrocarbons (PAH), light absorption

Page 5 of 42(aethalometer) and particle size distr i butions at t he Shoreham North site; daily PUF sampling for organic ana lysis and d a ily filter sa mpling usin g PM 2.5 speciation sam p lers at bot h Shoreh a m sites, collect i ng 24-hour fine particle samples for subsequent lab analyses for gravi m etric mass, major inorganic ions (SO 4 =, NO 3 -, Cl-

, NH 4 +), ele m ental and organic carb on and trace elements by X

- Ray Florescence (X RF); and an 8-stage DRUM sampler (Davis Rotating Unit for Monitoring) at both Shoreham sites which colle ct size-fra ctionated particle samples in 8 size ranges: 10 to 5.0 um, 5

. 0 to 2.5, 2. 5 to 1.15, 1

. 15 to 0.75, 0.75 to 0.5 6 , 0.56 to 0

. 34, 0.34 to 0.26, 0.26 to 0.09 um. It was the DRUM samplers where the most likely signatu r e of the trial burn on ambient air qua lity levels was expected to be found.

The trial bu rn began on Monday Nove mber 6

, 2006 with baseline te sting of the Power boiler

with the nor mal fuel mix of bark a nd oil and no TDF. B a seline part i culate emissions were

measured a t a respectable 0.043 lbs/MMBtu for this boiler. TDF was first fired in the Power

boiler on T uesday November 7, 2006 at a ra te of 0.5 to ns per hou r and soon thereafter

increased to 1.0 tons p e r hour. IP monitored boiler operation at this rat e throughou t the day but

did not con duct sta ck t e sting for p a rticulates t h is day. TD F feed was shut off f o r t he night an d resumed again Wednesday mornin g. IP again monitored boiler oper ations while firing TDF throughout t he day and most of th e evening at this rate a nd began p a rticulate m a tter stack testing on Thursday morning. The preliminary results sh owed particulate emissions to be

elevated at 0.08 to 0.09 lbs/MMMBt u in the first two test ru ns. TDF fe ed was shut off followin g these preliminary results without a th ird test run and resumed Friday at 0.5 tons per ho ur. Stack testing at th is rate on Friday again showed elevated preliminary parti culate matter emission
rates of 0.0 77 and 0.0 83 lbs/MMBtu. On Friday evenin g TDF feed was shut off for th e weekend. On Monda y morning, TDF feed commenced at 0.25 ton s per hour and three particulate matter stack test runs were completed before shutting off TDF feed f o r the night

. This was the last time TDF was fired in the boiler. On Tue sday Nove mber 14, 2006 IP reported
the result fr om the prior day’s three stack test r uns as 0.10 5 lbs/MMBt u , 0.105 lbs/ MMBtu, and
0.070 lbs/M M Btu. Give n the operat ional experience the trial burn of T D F provided to date, at
noon on N o vember 1 4 , 2006, I P announced that th e trial burn was bein g terminated immediately.

Even though the tria l b u rn ended earlier than expected a nd without conducting t he detailed

stack testin g that was scheduled to be completed the second week, signif i cant ambient monitoring data from th e Vermont s i tes were available to evaluate the potential impacts of the

shortened t r ial. A det ailed review of this am bient data indicated th at there were slight

increases in zinc and ot her metals detected du ring the tria l but all impacts were st ill well withi n state and federal health standards. These incr eases appe ar to have b een caused in part by a regional tra n sport event that raise d impacts at monitors all over New England dur ing this time

and which make it diff icult to disce r n IP’s contr i bution. Had the tria l b u rn continu ed for the fu ll expected duration or ha d IP burned TDF at the ex pected higher rates o f two and th ree tons per hour it may have been possib l e to more accur a tely detect the impact s of the tr ial burn. The testing completed during the trial burn did however confirm Vermont’s i n itial concer ns that IP’s existing air pollution co ntrols were not adequat e and that a d vanced emission s contr o ls would be necessary t o burn TDF in an environment ally sound manner at this facilit y.

Page 6 of 42Overview o f Events Preceding the Trial Burn

In Septemb e r of 1997 I n ternational Paper Co mpany (IP) conducted a very limited trial burn of

crumb rubber in the Po wer boiler at the Ticon d e roga mill. A total of 4 t ons of t i re crumb rubber

was burned over a period of two days. Other tha n the cont in uous emission monitors for carbon monoxide, n i trogen oxides and su lfu r dioxide no ac tual stack emission t e sting was conducted. Ash samples from the bottom ash and multicyclone (prior to the wet scrubber) were collecte d and analyzed. The effect of tire fuel on air pollution emission s was largely left unknown.

In Septemb e r of 2003 IP submitted a request to the State of New York De partment of

Environmen tal Conservation (NYDEC) for appro v al to once again condu ct a trial bur n of tire fuel in the Power boiler. This time IP proposed to b u rn shredded tires, refer r ed to as tir e -derived

fuel (TDF), at a rate of up to 3 to ns per ho ur; which is a pproximatel y 10% of th e heat input capacity of t he boiler (although it ge nerally operates at a rat e much less than this). The Power

boiler is an 855 million BTU per ho ur boiler that burns predominantly No.6 fuel oil. The Power

boiler al so h a s sol i d fue l burning ca pability and typically burns wood/bar k at a rate o f 425 ton s per day. This is appro x imately 17 7 million BT U per hour of heat inpu t or 20% of capacity. IP proposed to maintain th e wood/bark firing at a constant rate and mix in increasing a m ounts of
TDF as No.6 fuel oil was to be de cr eased prop ortionately. TDF use at the facility was intended to displa ce No.6 fuel oil usage and l o wer the mill's energy co sts.

It was proposed that the trial burn would take place over a period of up to 30 days and include

extensive stack emissio n testing. E m issions da ta would be colle cted both when the boile r burned the TDF and when it did n o t. This would pr ovide c o mparative emission data that could be used in support of a possible fut u re permit application fo r permanent approval to burn TDF.

On January 26, 2004 t he NYDEC determined that a form al applicatio n to amend the existin g Title V Air Permit was required. One year l a ter on February 1, 2 005 IP filed the Title V

amendment applicat ion with the NYDEC. T he NYDEC determined the application to b e incomplete on March 10, 2005. IP subsequently addressed the deficiencies in the initial application and resubmitted it July 6, 2005. On August 18, 2005 the Vermont Agen cy of Natura l Resources ( A NR) hoste d a public informational meeting to enable the public to he ar from and ask questio n of International Paper and opposition groups regarding the tire burning issue. On October 12, 2005 the NYDEC issued a “Draf t ” Title V Air Permit to the International Paper Compan y a pproving the trial burn of TDF at their Ticondero ga, NY mill. The NYDEC held their official public hearings to take comments on the draft permit on Nove mber 9, 2005 and

Nove mber 30, 2005 at t he Ticonder oga Armory Communit y Center located at 123 Champlain

Avenue in T i conderoga, N.Y. In ord e r to facilitat e public inp u t on the draft permit from Vermont

citizen s , Vermont ANR also held a public meeting to take comment o n the draft permit from

those unable to attend the NYDEC meeting or who prefer red to make their comments at th is meeting instead. The meeting wa s held on T uesday November 15, 2005 at the Middlebury
Union Middle School located at 48 Deerfield Lane in Mi ddlebury, Vermont. Vermont ANR

transcribed t he proceedings of the meeting and subm itted this transcrip t to the NYDEC as part of the public record. T he State of Vermont also submitte d its own comments o n the “Draft” permit to the NYDEC on December 2 3 , 2005.

On February 8, 2006, the State of Vermont, through the Office of the Attorney Gen e ral, filed a n action in New York state court against NYDEC a nd IP to blo ck the proposed tire burn. Vermont alleged that NYDEC failed to compl y with New York’s State Environ m e n tal Quality Review Act (SEQRA). The court, h o wever, held that NYSDEC had fully complied with SEQRA.

Page 7 of 42On July 27, 2006 the NYDEC released their Response t o Comment s received on the “Draft” permit and sent a “Pro posed” permit to the US EPA Regi on II for the i r 45 day re view period. The “Proposed” permit still intende d to allow t he trail burn to proceed under certai n conditions and requirements. On September 11, 2006, EPA’s 45-day period for reviewing th e proposed permit modifications ended, and EPA did not issue any objections. On September 12, 2007, the
State of Ver m ont submitted a petit ion to EPA to object to the proposed permit modifications and further requested that EPA direct NYDEC to refrain from issuing to IP a modified permit or suspend an y permit issued pending resolution o f Vermont’s petition.

On Septe m ber 20, 2006, NYDEC i ssued a fin a l permit modification t o IP approving the trial

burn. Under the terms of the permi t issued, IP was required to provide 30 days no tice before initiating the trail burn. On October 5, 2006, IP notified NYDEC that it proposed to commence a trail burn of TDF in its p o wer boiler on Nove mber 6, 2006.

On October 10, the Stat e of Vermont, through th e Office of t he Attorney General, file d a petit ion
with the Second Circuit Court of Appeals reque sting that th e court enjo i n IP from commencing

the test burn until EPA issued a decision on Vermont’s petition objecting to the permit
modification s. On No ve mber 3, 200 6, the court denied Vermont’s petition. IP commenced the

trial burn on Nove mber 6, 2006 with baseline t e sting of th e Power boiler with normal fuel mix

and no TDF. TDF was first fired in t he Power boiler on Tue sday Nove mber 7, 2006. TDF was
then fired Wednesday, Thursday and Friday of that week and shut off Friday eve n ing for the
remainder of the weekend. TDF wa s again fired in the boiler on Monday morning No vember 13
and shut of f at approximately 10:00 pm that evening. The trial bu rn was ter m inated on Tuesday November 14 without firin g any TDF t hat day.

Page 8 of 42On-Site Tri a l Burn Ob servation Summaries

The complete field repo rts containin g the trial b u rn observations by the on-site Vermont ANR personnel f o r each day of the trial are contain ed in Appendix I. Below is a summary of eac h days’ events during the t r ial burn.

(Day 1 - Mo nday No ve mber 6, 200 6) In accordance with the permit, t he first day of the trial was to begin with baseline emission testing for particulate matter under normal firing of fuel oil and
bark before TDF could b e added. As a re sult o f unanticipat ed problems with the ba rk fuel feed system in the morning (unrelated to TDF) the baseline testing was delayed and not complete d until approximately 6:00 PM. Upon completion of the baseline testing, I P decided t o wait until Day 2 before beginning any burning of TDF.

The results of the baseline particulat e matter testing was rep o rted as 1 :

Run 1 0.038 lbs/MMBtu

Run 2 0.040 lbs/MMBtu

Run 3 0.051 lbs/MMBtu Average 0.043 lbs/MMBtu

1 Results are p r elimi nar y a nd subj ect to chan ge bas ed o n re vie w of fina l stack test report.

(Day 2 - Tuesday Nove mber 7, 2006) At approximately 8:1 5 AM on the second d a y of the trial
the TDF fee d system was first turn ed on; adding TDF to t he bark fuel feed at a ra te of 0.5 tons of TDF per hour. Due t o delays in the delivery of fuel from the wood yard to the bo iler it was estimated that TDF was not actually being burne d in the boiler until appr oximately 8: 55 AM. At approximate l y 10:45 AM the TDF fe ed rate was increased to 1.0 tons per hour. Ba sed on our

visual obser vations of the TDF feed where it drops into t he bark fue l feed we requested to

review the c a libration da ta and to have IP condu ct a one point check of the TDF feed to verify the accuracy of the feed rate. This test wa s scheduled for the following day (day 3). In

accordance with the permit, particulate matter testing must also be com p leted at the 1.0 ton per hour TDF firing rate that demonstrates complian c e with the Power boiler emission limit of 0.10
lbs PM/million BTU before the TDF feed rate can be in creased to 2.0 tons pe r hour. IP continued with the 1.0 ton per hour TDF feed rate until approximately 7:00 PM wh en they shut off the TDF feed for the night. Again, due to delay s in the fuel feed it was assumed that by 8:00

PM the boiler had burned all the TD F that had b een added t o the system.

(Day 3 - Wednesday November 8, 2006) The third day of the trial b e gan with th e TDF feed system being turned on at 5:15 AM at the rate o f 0.5 ton s p e r hour. This was qu ickly increased

to 1.0 tons per hour at 6:00 AM. The boiler o p e rato rs cont inued to monitor the bo iler at the 1.0 ton per hour feed rate throughout the day. At 10:20 AM th e TDF feed system was audited to verify the accuracy of th e TDF feed rate. The a udit yielded a rate of 1.0 5 tons per h our at the 1.0 ton per hour setting and was co nsidered suf f iciently accurate and re presentative. IP opted

to continue firing TDF at the 1.0 ton per ho ur rate thro ughout the night, with an expected interruption from approximately 2:00 AM to 4:00 AM for normal mainten ance, in order to allow

additional b o iler operat ors to gain experience with the fue l . No stack emission t e sting was

conducted t h is day.

(Day 4 - T hursday No vember 9, 2006) Follo wing the shutdown of the TDF fee d for norma l maintenance at 2:00 AM Thursday morning, the TDF feed was turned back on at 4:30 AM at the rate of 0.5 tons per hour. By 5:00 AM this was increased to 1.0 tons per hour. IP began the first Method 5 particulate m a tter test at the 1.0 ton s per hour f eed rate at 9:15 AM and began the

Page 9 of 42second test run at 11:10 AM. Durin g both particulate matter test runs o b servations of the CEM system displays indicat ed NOx and SO 2 emissions were within permit limits. The preliminary particulate matter results for the two runs were reported as 0.089 lbs/MMBtu and 0.082
lbs/MMBtu. The preliminary results are based only on the filter weights, which are still subject to change as t hey equilibrate. The preliminary re sults do not include the probe wash component of the test runs which requires the samples be placed in a n oven for several hours until the liquid fraction evapora t es off, leaving the pa rticulates collected by the probe wash to b e weighed. Since the preliminary pa rticulate matter emission rates were higher than expected

with minimal margin of c o mpliance, IP decided to shut off the TDF feed at 4:00 PM f o r the rest of the day and did not complete a third particulat e matter test run.

(Day 5 - Fri day No ve mber 10, 2006) On the 5 th day of the trial, the refined results of the two particulate matter emission test runs comple ted the da y before were reporte d as 0. 109
lbs/MMBtu and 0.093 lbs/MMBtu, re spectively. The permit limit is 0.10 lbs/MMBtu. The refined

results in clu de both the filter weight and probe wash component but are still sub j e c t to change slightly as t he data and calculat ion s are verified and prese n ted in a fin a l stack t e st report that typically follows within 30 days of the testing. Based on these refined results IP re started the
TDF feed at 5:00 AM at the 0.5 tons per hour fe ed rate with intentions of conducting particulate
matter tests at this lower feed rate. The f i rst particulate matter test run was started at approximate l y 11:00 AM and the second run was starte d at approximately 3:45 PM. Th e preliminary test result s for these two test runs were reported as 0.077 lbs/MMBtu and 0.083 lbs/MMBtu, respectively. Based on these highe r than expe cted preliminary results, IP ceased
TDF feed at 5:30 PM fo r the weeke nd. IP in te nded to exp l ore options for reducing emissions

over the we ekend, inclu d ing ways t o optimize the wet scrubber, before commencin g TDF firing again on Monday mornin g Nove mber 13 th

.

(Day 6 and 7 - Saturday No vember 11 and Sunday Nove mber 12, 2006) Over th e weekend of

Nove mber 11 th and 12 th , IP made adjustments to the spray patterns in the wet scrubbe r pollution control device. These adjustment were compl e t ed with the expectation it would improve the performance of the wet scrubber and achieve greater particulate matter remo val. No TDF wa s burned over the weekend.

(Day 8 - Mo nday No ve mber 13, 20 06) On November 13 th TDF was re -introduced to the powe r boiler fuel mixture mid-morning. The feed rate of the TDF was limited to 1/4 ton per hour. A particulate t e st was completed this day and produced a preliminary re sult of 0.06 5 lbs/MMBt u

. IP planned to conduct a second test at this feed r a te before deciding next steps. On Monday at approximate l y 10:00 AM the TDF fe ed was rest arted at a ra te of 0.25 to ns per hour. Particulate matter testing at this level began i n the early afternoon. The preliminary results from the first test were reported as 0.07 lbs/MMBt u . This included an estimate of the probe wash component.

Two additional test runs at the 0.25 ton per hour TDF feed rate were completed that afternoon and evening (the 3 rd ru n failed the leak test a nd had to b e repeated). The fina l t e st run was completed around 10:00 PM and TDF feed was shut off at t h is point for the night. Preliminary
results from the last two test runs we re not provided that evening.

(Day 9 - Tuesday Nove mber 14, 2006) On Tuesday morning the refine d results from the three particulate t e sting run s at the 0.2 5 tons per hour TDF feed rate were reported as 0.105 lbs/MMBtu, 0.105 lbs/ MMBtu, and 0.070 lb s/MMBtu, respectively. These r e fined results

included the probe wash component in additio n to the filte r weight. The initial e s t i mate of the probe wash component for the first run the prior day was shown not to be accu rate as the refined results showed the probe wa sh component to be more significan t than with prior tests at

Page 10 of 4 2higher TDF levels. At approximately noon IP announced that it would cease the trial immediately. No TDF was fired this day.

As emission s measured under this trail burn pr ogram indicated that emissions w h ile burning

even the lo west amount of TDF re sulted in e m issions ve ry close to the permit limit of 0.10
lbs/MMBtu. IP conclude d that furthe r testing would not b e u s eful and th at the trail p r ogram had yielded data that support ed not going forward with TDF as a component of the Power boiler fuel.

Page 11 of 4 2Ambient Ai r Monitorin g

Introduction

The Vermo n t ANR mai n tains a stat ewide network fo r routine monitoring of ambient air quality. Beginning in late 200 3, this stat ewide network was su pplemented with spe c ial purpose monitoring at two loca tions in Sh oreham, Ve rmont. There were two monitoring sites in
Shoreham f o r this Special Study. They were generally referred to a s Shoreham North and
Shoreham South. The Shoreham No rth site was located on L apham Ba y Road, about a quarter
mile east of Lake Cha m plain. The Shoreham South site was located just off of Smith Stree t,
near Route 74. The Shoreham North and Shoreham South monit o ring sites were selected

based on m a thematical model simulation of wer e it was expected that th e plume for m the power

boiler stack would have its maximu m impact in Vermont.

The two Sh oreham mo nitoring stations were fitted with instruments to collect dat a as to the

ambient air concentratio n s of particu late matter in two particle size range s; 10 microns and less (PM 10 ) and 2.5 microns and less ( P M 2.5 ). The devices t o colle ct th ese data also allow th e samples to be analyzed for specific particulate compounds (chemical speciation) . Samples

were collect ed every si x (6) days beginning in late 2003 until just prior to the trial burn when sampling was increase d to every da y.

To aid in th e understan ding of the air quality data, instruments to reco rd meteorological data

was located at the Shoreham North site.

Vermont ANR Intensive Sampling

On 10/26/0 6 , intensive daily, noon to noon sampling for p a rticulate (b oth PM2.5 and PM10) began. The intent was to collect d a ily values before the commence m ent of the trial burn on

Nove mber 6th. One 10/ 26/06 sample was missed because that sampler was reco nfigured for daily, noon to noon sampling on that day (prior to this day this was the sampler used to trial the daily operating mode). On 10/29/06, three of four samples were lost because th e samplers were mistakenly operated in field b l a n k mode. On 10/30/06, all four samples were lo st becau se of operator error. Single samples o n 11/5/06 & 11/23/06 were invalidated due to in strumental and laboratory errors. There was 92% data capture for these samples, which represent s excellent sa mpler and personnel per formance.

During this intensive sa mpling period the Shoreham Nort h meteorological syste m operated

without incid ent. Meteorological dat a collection also began at Shoreham South at t h is time. The

electronic w i nd speed and wind direction sensor on the Shoreham So uth sampler failed on o r about 11/1 2 /06. For this reason, there is o n ly wind speed and wind direction from the
Shoreham South site for 10/28/06 to 11/11/06. Both PM1 0 and PM2. 5 ambient monitoring dat a for Shoreham North an d Shoreham South fo r the intensive sampling period are presented

below.

Page 12 of 4 2

### Vermont ANR Intensive Sampling Month Results

Sample Date Shore ham North

PM 10 (24 h r ug/m 3 ) Shore ham So uth

PM 10 (24 h r ug/m 3 ) Shore ham North

PM 2.5 (24 h r ug/m 3 ) Shore ham So uth

PM 2.5 (24 h r ug/m 3 )

Date/NAA QS 150 ug/m 3 150 ug/m 3 35 ug/m 3 35 ug/m 3

10/26/20 0 6 3

. 5 n a 2

. 1 1

. 6

10/27/20 0 6 4

. 3 4 1

. 5 2

. 6

10/28/20 0 6 1

. 4 1

. 5 1

. 2 1

. 2

10/29/20 0 6 n a 1

. 8 na na

10/30/20 06 na na na na

10/31/20 0 6 1 6

. 8 1 5

. 6 1 0

. 7 6

. 2

11/1/200 6 1 0

. 2 7

. 8 5

. 6 5

. 3

11/2/200 6 6

. 3 6

. 2 3

. 8 4

11/3/200 6 3

. 8 2

. 4 2

. 2 1

. 3

11/4/200 6 8

. 7 7

. 8 5

. 6 5

. 9

11/5/200 6 2 0

. 2 n a 1 2

. 9 1 3

. 2

11/6/200 6 2 8

. 5 2 3

. 3 1 6

. 3 1 6

. 9

11/7/200 6* 29.3 26.2 19.4 20.8

11/8/200 6* 12.2 9.8 10.5 8.8

11/9/200 6* 9.2 9 7 6.5

11/10/20 06* 6.2 5.5 3.6 3.4

11/11/20 0 6 6

. 7 7

. 4 5

. 3 5

. 8

11/12/20 0 6 4

. 5 4

. 3 3

. 2 3

. 4

11/13/20 06* 7.8 7.7 5.5 5.2

11/14/20 0 6 3

. 9 4

. 6 2

. 1 2

. 6

11/15/20 0 6 1 1 1 0

. 4 7

. 9 7

. 5

11/16/20 0 6 8

. 7 7

. 3 4

. 3 4

. 3

11/17/20 0 6 1

. 9 1

. 9 1

. 2 1

. 1

11/18/20 0 6 4

. 1 4

. 1 3 2

. 7

11/19/20 0 6 3

. 4 3

. 5 2

. 2 2

. 4

11/20/20 0 6 3 3 1

. 7 2

. 3

11/21/20 0 6 8

. 3 6

. 6 5

. 1 5

. 4

11/22/20 0 6 1 2

. 1 1 1

. 7 8

. 5 9

. 9

11/23/20 0 6 2 2

. 2 2 2

. 5 1 7

. 1 n a

Page 13 of 4 211/24/20 0 6 1 1

. 7 1 0

. 3 6

. 9 6

. 9

11/25/20 0 6 2 0

. 4 1 6 1 0

. 6 1 0

. 4

11/26/20 0 6 2 7

. 6 25.9 17.6 17.9

* TDF was b u r ned at IP on these d a tes.

Page 14 of 4 2Contracted Private Res earch Group Sampling

To supplement and enhance the VTANR air qu ality measurements, ANR contracted with three external research groups to conduct air quality monitoring activities a t the Shoreham sites.

These rese arch group s included: Ecosystems Research Group (Dr. Eric Mille r), Clarkson University (Dr. Phillip Hopke), and t he DELTA Group at U. California, Davis (Dr. Thomas Cahill).

Ecosystems Research Group (ERG) measured gaseous elemental, reactive g a seous an d particulate mercury using a Tekran semi-contin uous analyzer at the Sh oreham North site from
10/18/06 thr ough 12/7/0 6 . Dr. Miller was al so making simi lar concurrent Hg measurements at

the rural Underhill, VT site. The
Tekran in S horeham was operated to
collect and analyze 2-hour avera g e

samples every 3 hours. Dr. Miller also opera t ed a meteorologica l

station and a web ca mera (imag e refreshed e v ery 5 min u tes) pointe d

at the IP stack and from which

i m a g e s h a v e b e e n a r c h i v e d

. A n example ph oto is d i spla yed in Figur e 1. Note th e corner of the Clarkso n University monitoring shelter in t h e foreground and the IP plume in th e b a c k g r o u n d (this was not a TDF test

u r n d a y )

. Figure 1. WebCam Image from Shoreham

North Moni toring Site (10:06 AM o n 11/15/06)

b

Dr. Hopke’s Clarkson g r o u p r a n samplers at both Shoreham sites from 11/4/06 through 11/27/06. A t the northern site, they made (o r attempted – there were several equipment and detection limit problems) contin u o s h o u r l y

measureme n ts of PM u

2.5 mass by F D MS T E OM (Filter Dy namic Measurement Syst em, Tapered

Element Os cillat i ng Microbalance), SO 2 gas, SO 4 aerosol, organic car bon, elemental carbon, polycyclic a r omatic hyd r ocarbons ( PAH), light absorption (aethalometer) and particle size

distribution s . With daily filter-chang ing assistan ce from VT APCD, the Clarkson g r oup also

conducted daily PUF sampling for organic analysis and daily filter sampling using PM 2.5 speciation samplers at both Shoreham sites, collecting 24-hour fine particle samples for

subsequent lab analyses for gravimetric mass, major inorganic ion s ( S O4 = , NO3 - , Cl - , NH4 + ),

elemental a nd organic carbon and trace eleme n ts by X

- Ra y Florescen c e (X RF). T he Clarkson mobile sampling van that contained most of t heir continuous instruments at the Shoreham north

site is show n in Figure 2. Also sho w n are the Clarkson T E OM, VT DEC Meteoro l ogy sensor s and the ERG Tekran a nd met s y stem, all mou n ted on top of the VT DEC monito ring shelter (behind the Clarkson van). The UC Davis DRUM sampler, VT DEC PM 2.5 sampl e r and the
C l a r k s o n P U F s a m p l e r a r e i n t h e f o reground.

Page 15 of 4 2Figure 2. Air Sampling Equipment at the Shoreham North Monitoring Site

Dr. Thomas Cahill’s DELTA group at UC Davis provided two 8-stage DRUM sa mplers (Davis Rot a ting Unit for Monitoring),

which were run at both Shoreham sites from 11 /1/06 throug h
11/30/06. The DRUMs collect size-fractionated particle samples in 8 size rang es: 10 to 5.0 um, 5.0 t o 2.5, 2.5 to 1.15, 1.15 t o 0.75, 0.75 to 0.56, 0. 56 to 0.34, 0.34 to 0.26

, 0.26 to 0.09 um. Sa mples are deposited on greased Mylar strips, affixe d to the outside of slow ly rotating “drums”. Afte r sampling, the individual strips can then be subject to analyses for mass (beta attenuation), optical att enuation (for multiple wavelengths), a nd multiple elements by Synchrotron

X

- Ray Flore scence (S-XRF), with a temporal re solution of 1

to 3 hours. The DRUM sampler is displayed in Figure 3. A pump beneath the sampler draws air through a PM 10 inlet an d deposits the particle s in progressively smaller size ranges o n Mylar strips attached t o t h e 8 s l o w l y r o t a t i n g d r u m s

, clockwise fr om upper right to upper left.

Other sources of supplemental monitoring data include routine monitoring data f r om other VT sites durin g the month
of Novembe r 2006, which can provid e a more re gional conte x t to the inte nsive monitoring at the
Shoreham sites. These include the speciated PM 2.5 data fr om every 3 rd day filter sa mpling from Figure 3. UC Davis DRUM

Page 16 of 4 2the EPA Sp eciation Trends Network (STN) site in Burlington, continuous PM 2.5 mas s data from

sites in Burl i ngton, Rutland and Underhill, VT, a nd hourly SO2 from rural sites in n o rtheastern NY. For example, the h ourly PM 2.5 mass data fr om Burlington, Rutland and Underhill are plotted in Figure 4 along with a photo of th e 8 DRUM sample strip s - which cover the same 1-month period from left to right, with the larg est particle sizes (10 to 5 microns o n top and th e smallest (0.26 to 0.29 microns on the bottom). It can be noted that the darkest section s of the DRU M strips, ind i ca tive of light absorbing carbonaceou s particle s and most evi dent in the smaller sizes (<0.56 microns), correspond to multi-day regional PM 2.5 eve n ts from rou ghly No vember 5-8 and

Nove mber 2 5 -28.

Figure 4. Hourl y VT PM 2.5 data (top) and Photo of Shoreham North DRUM stri ps (bottom)

Page 17 of 4 2The CALPUFF modeling describ ed in Appendix 3 can be considered as an add itional form of augmented data related to the measurements from the Sho r eham moni toring site s. The model

was run wit h the constant generic emission rate (10 lbs./hr.) for the IP boiler stack. Detailed 3- dimensional meteorological f i elds were developed using th e CALMET model with inputs of the
VT DEC s u rface meteorology measurements from the Shoreham North site (no met

measureme n ts for the South site d ue to data logger malfunction), win d fields dev eloped fro m National W eather Service meteor ological models, and detailed local terrain d a ta. Spatia l depictions o f the daily CALPUFF mo del results f o r the period of No vember 5 th through 14 th are presented in Appendix 3. The m odel results were also polled to pr ovide hourly time series estimates of relative pl ume i m pacts at the Sh oreham North and Sout h monitoring sites, as displayed in Figure 5 below. Note that for the Shoreham North site (due north of the IP plant

and where most of the ambient measurements we re take n), the periods of modeled source impacts coincidentally correspond to the multi-day regional PM 2.5 e v ents on Nove mber 5-8 an d

Nove mber 2 5 -28 as indicated in Fig u re 4.

Figure 5. Relative CALPUFF Mode led Plume Impacts at the Shoreham Monitori ng Sites

It can be not ed that during the days of the TDF t e st burn there were esti mated plume impacts at the North site (11/7 and 8) and South site (11/9 and 10) with maximu m ho urly relative

concentratio n s (at a generic emissio n rate of 10 lbs/hr) in the range of 0.2 to 0.5 ug/m3. With an estimated heat input for the IP boiler (from all fuels combined) of about 500 to 6 00 MMBtu/hr and a permit-limited PM emission rate of 0.1 lbs/MMBtu (measured during part s of the TD F test), an a c t ual PM emission rate of up to 50 or 60 lbs/hr is a reasonable estimate o f maximu m hourly PM e m issions fro m the IP plant during the TDF test b u rn, and mo deled hourly particulate matter source impacts a s high a s 1 t o 3 ug/m3 a nd daily impacts of up to 0.1 to 0.6 u g /m3 might have been expected at the Shoreham monitorin g sites dur in g the TDF test burn.

Page 18 of 4 2Quality Ass u rance Comparison of Similar Measurements

The assorte d Shoreham and other VT

measureme n t data include a number
of redundant or semi-redundant

measureme n ts (approximately the same thing measured more than 1 way). Comparisons of these

redundant measureme n ts provides
an extra measure of co nfidence in (or raises questions about) the quality of the individu al

measureme n t data. Figure 6 compares the daily f ilter-based

measureme n ts of PM 2.5 m a ss from the samplin g conducte d by the VT DEC using Federal Reference Method (FRM) PM 2.5 sam p lers with

the con c urrent filter-based

measureme n ts conduct ed by the
Clarkson group using PM 2.5 speciation samplers. Figure 6. Comparison of dail y Sh oreham PM 2.5 filter

measurements b y VT DEC and Cla r kson

Figure 7. Compariso n of dail y Shoreham PM 2.5 mass b y VT DEC FRM Filter and Clarkson TEOMs While the Clarkson filt er-based PM 2.5 mass measurements compare well

with the collocated V T DEC F R M samples at both Sh oreham sites (adding co nfidence to both se ts of

measureme n ts), the Clarkson TE OM

PM 2.5 data, aggregated to the same 24-hour per iods for which the filter sampling was conducted

, do not agree

very well (Figure 7) with the VT FRM data, espe cially at t h e S h o r e h a m South site. There were al so operational problems with the TEOM
at the Shoreham North site, re sulting in invalid data prior to 11/11/06, missing all but the last day of the T D F
test burn. So the Clarkson TEOM

data will n o t be used i n subseque nt analyses. Additional comparisons can be made

between the elemental concentration
data from the Clarkson da ily speciation filter samples and the U. C.

Page 19 of 4 2Davis DRUM data, agg regated to a similar size range and averaging times. The Cl arkson PM 2.5 speciation samplers ran for 24 hour s, (approximately) noon to noon, on Nove mber 4-26, 2006. Davis DRUM Syncratro n X R F data were aggregated to the same (<2.5 micron) size range (sum
of 6 smallest DRUM sta ges) and to the same 24-hour sample periods (average of eight 3-hour samples) fo r direct comparison. An Average 24-hour value was ca lcu l ated by averaging daily
values from both labora t ories and f o r both site s. Values f r om the individual labs and sites (Y axis) are co mpared to the 4-sample daily averages (X axi s ) in the fo llowing plots for sulfur, aluminum, iron, calcium, vanadium and zinc (S-ND = sulfur, north site, Davis analysis; S-SC = sulfur, south site, Clarkson analysis)

.

Figure 8. Dail y PM 2.5 S and Al from Clarkson Filter XRF vs. DRUM Sy nc ratron XRF

Figure 9. Dail y PM 2.5 Fe and Ca from Clarkson Filter XRF vs. DRUM Sy ncratron XRF

Page 20 of 4 2Figure 10. Dail y PM 2.5 V and Zn from Clarkson Filter XRF vs. DRUM Sy ncratron XRF

Generally, t he Clarkson 24-hour PM 2.5 filter results agree reasonably well with the time and sizeaggregated UC Da vis Syncratron XRF results. In most cases correlat i ons (R 2 ) are > 0.85 and slopes are within 20% of 1:1. On e exception is that the vanadium and zinc da ta from the
Clarkson filt ers from the Shoreham South site are roughly 40% lower than the average DRUM results, with correlations (R 2 ) of 0.53 and 0.63 respectively.

Figure 11 compares 3-hr. Zn data from stage 7 (0.24 to 0.36 μm) D R U M s a mples at the
Shoreham North and South sites, with T D F test burn days and all other days during

Nove mber 2006 displayed separately. The co rrelation (R 2 =0.78) is much stron ger on non-test burn days, suggesting
influence of a regional source impacting both site s concurrently. Highe st Zn

concentratio n s at both sites

were observed on TDF test burn days, and the cor r elation is much lower (R2=0.38), suggesting a nearby local source imp a cting each site at
different times. Figure 11. DRUM Stag e 7 Zn from Shoreham North & So uth

Page 21 of 4 2Regional Background

As indicated in Figure 4

, there were several periods of heavy loading on the Shoreham DRUM samples tha t correspon ded to multi-day regional PM 2.5 events from roughly Nove mber 5-8 and

Nove mber 25-28, 2006. The hourly PM 2.5 data from the Burlington, Rutland and Bennington

sites can be aggregated to daily averages (for th e same noon to noon sample times for which the Shoreham filter samples were collected). T hese aggregated hourly data, combined with the
two sets of daily Shore ham filter meas urements provides 5 VT sites of daily PM 2.5 data from

which state w ide maxi ma and minima can be calculated . The Shoreham filter data and these statewide ranges are displayed in Figure 12. Th e minimu m values at all sites can be taken as a rough indica tor of statewide regional transport influences.

Figure 12. Range of Dail y VT fine particle concentrations during 11/06 Shoreham Intensive

Note that no VT sites experienced concentrations as high as the new 24-hour PM 2.5 national

health stand ard (35 ug/m 3 ). It can also be not ed that the first few days of the TDF test burn

occurred du ring a regio nal transpor t event. On most days, the concentrations a t the rural
Shoreham s i tes were at or near the statewide minima – such that whatever local influence s there might have been affecting th e Shoreham site s in Nove mber 2006, they were typically

much smaller than the local influen ces at the other (urban) VT sites during that time period.

Possible exceptions to t h is pattern o ccurred on Nove mber 7 and 8, when one or bot h Shoreham

sites were n ear the state w ide maxi ma.

Page 22 of 4 2Figure 13. Average Da il y Shoreha m Composition of Major PM 2.5 Ma ss-contributing Species

Figure 13 plots the average Shoreham daily fine particle composition of major PM 2.5 mas s contributing species based on the Clarkson PM 2.5 speciation filters from both Shoreham sites. OMC in this case represents “Organic Matter b y Carbon” an d is calculat ed as 1.6 times organic carbon (to account for unmeasured oxygen an d hydrogen associated with organic carbon in organic co mpounds). It may b e noted th at the hig hest November 2006 PM 2.5 m a ss concentratio n occurs on 11/7/06 – the first day of the TDF test burn, but with similarly high

concentratio n s on the preceding day. It can be noted that more than h a lf the PM 2.5 composition on 11/6 and 11/7 is composed of sulfate, nit r ate and ammoniu m

. Ammonium nitrate and

ammoniu m sulfate are “secondary ” pollutant s – primarily formed in the atmosphere from
reactions of precursor g a ses - sulfur dioxide, nitr ogen oxides and ammo nia. Second ary aerosol formation takes time, and sulfate and nitrate concentrations in VT are p r edominantly the result of regional tr ansport fro m high SO 2 and NOx e m itting regions to our so uth and west.

The Top ro w of Figure 14 shows NOAA HY-SPLIT mod e l 48-hour backward a i r trajectory

calculat ions arriving at a height o f 500m at Shoreham eve r y 2 hours on Novemb er 6 and 7, 2006. The trajectories indicate synoptic sca le t r ansport primarily fro m t he Midwest on 11/6 with increasing l y southerly flows on 11/7 from majo r source re gions in bot h the Ohio River Valley
and East Coast urban corridor. Th e bottom row of Figure 14 shows surface wind vectors from National Weather Service observations at 18:00 UTC (1 PM Eastern Standard Time) on 11/6

and 7 overlain on dai ly Satellite i m ages from the NASA MODIS sensor (data obtained via http://datafe d .net ). The surface win d s are sout h/southwest e rly on 11/6, switching t o strong an d persistent southerly flows on 11/7. Thus we might expect t r ansport fro m both the Midwest and
East Coast along with high concen trations of secondary sulfate and nit r ate (and coal and oilassociat ed trace elements like Se, As, V and Ni) on and just before the first few days of the TDF test burn, making it diff icult to sort out influences of local and distant sources. T he transport

winds weakened and b e came less organized o n 11/8-13, a s the Shore ham ammo nium sulfate

and ammoni um nitrate levels dropped considera b ly during the course of t he TDF test burn.

Page 23 of 4 2Fig 14. HY-SPLIT 48-hr Back Trajectories from Shoreham on 11/ 6 & 7, 2006 and Surface Wind Vectors(NOAA) w i th MODIS Satellite images on 11/6 & 7, 2006

Figure 13 also shows that the levels of organic matter (OMC) in Shore ham peak slightly after
the sulfate a nd nitrate, r eaching maximu m concentrations o n 11/8 and 11/9 during the middle of TDF test burn. VT organic aerosol concentratio n s can result from both regional tra n sport and

local sour ce s (woodstoves, automotive emissions, and some point sour ces) with lo cal source s relatively more important in colder weather. If there were a perceptible PM 2.5 m a ss increase in
VT from the TDF test burn, its like l y that OC would represent a high proportion of that impact

. On average , the Clarkson filter PM 2.5 concentr a tions on T D F test bur n days were 20% high er than on non-test burn days, but OC concentrations were 40 % (about 0. 8 ug/m3) hi gher on TDF burn days.

Page 24 of 4 2Limited additional VT sp eciated fine particle data is available from 1-in-3 day sample s from the EPA Speciation Trends Network (STN) site in Bur lington. Major mass-contributing species from same day samples in Shoreham an d Burlington are compared in Figure 15. Unfort unately, the 2 days – 11 /10 and 11/13 – when TFD testing was conducted and when speciate d data were
available from both sites – were not days when t he CALPUF F modeling indicated impacts from

the IP sour ce at eithe r of the Shoreham sites. Nevertheless, it can be see n that PM

concentratio n s – especially of organ ic matter – were typically several ug/m 3 higher i n Burlington
than in Shoreham. Th us the IP boiler - burning its stand ard mixture of residual oil and wood waste or with supplemental TDF fuel - appe ars to add less to th e regional backgroun d

concentratio n s in Shore ham than is contributed by local so urces in ( s mall) urban areas like Burlington.

Figure 15. Comparativ e PM 2.5 Sp eciation data from Shoreham and Burlington, Nov. 2006

As previously indicated, the abbreviated 5-day p e riod of the TDF test burn included only a few days when meteorological condit i o n s were “favorable” for impacts at either of th e Shoreham monitoring sites. Rela tively small amounts of TDF (not exceeding 1 ton/hour) were burned during the t e st (in combination with the plant’s u s ual mix of r oughly 10 to ns/hr of re sidual oil and
15 tons/hr of wood waste ) . The Shoreham North si te, where most measu r ements were taken, is downwind of the IP plant when local surface win d s in the Champlain Valley are from the south,

conditions which are typically associated with synoptic-scale flows from the south an d southwest, bringing transported pollutants from the East Coast Urban Corridor and Ohio Ri ve r Valley. Several days of the test bur n - including days of (small) modeled impact from IP at th e Shoreham sites - coin cided with regional transpor t from the south an d southwest

, making it especially difficult to d i scern impacts from t he TDF fuel from other coincidental influe nces.

Figure 16 is based on Shoreham OC, EC, SO 4 , NO 3 an d NH 4 data from the Clarkson filter

sam p les, SO 2 and PAH from the Clarkson cont inuous instru ments, and gaseous

Page 25 of 4 2elemental Hg (GEM), p a rticulate Hg (HGP), and reactive gaseous Hg (RGM) fro m the ERG Tekran. The bars display concentrations averaged for days of the TDF test burn (11/7, 8, 9, 10, 13/06) and for non-TDF test days ( m ost other days of November, 20 06). The r ed bars and right-hand Y scale show the ratios of the concentr a tions on T D F burn days vs. other days. Note that for most of these pollutants, th e ratios are within 30% plus or minus of 1:1, with the minor exception of organic car bon (about 40% higher on TD F burn days) an d the major exception of reactive gaseous mercury, for whic h Shoreham concentrations were more than twice as hig h during the T D F test burn than on oth e r Nove mbe r 06 days.

Figure 16. Shoreham North Conc entrations during TDF Test Burn and other 11/06 Da y s

A small influence on Shoreham rea c tive gaseous Hg concentrations fro m the IP pla n t burning its

routine mix of residual oil and wood waste would not be surprising ( both fuels contain trace levels of Hg), but an increase in mercury e m ission s from the additio n of TDF f uel was not expected, as the Hg co ntent of TDF is not estimated to be as high as f r om residual oil. It should be noted that the apparent increase in average Shoreham RGM on TDF test burn days is very small (1 pg/m3) and not statistically significa nt. It should also be noted that the average and peak RGM concentratio n s in Shore ham during Nove mber 2006 (mean = 0.33 pg/m3) were

substantia lly lower than concurrent RGM measur ements at the rural Underhill, VT site (mean = 2.89 pg/m3).

Page 26 of 4 2Figure 17. Gaseous El emental, Reactive and Particulate Mercury at Shoreham North

Figure 17 displays the time series o f the Tek ran measurements of gaseous elemental mercury (GEM), reac tive gaseous mercury (RGM) and p a rt iculate mercury (HGP) at the Shoreham North

site. While t he RGM co ncentrations are clearly elevated on the first 4 days of the TDF test burn,

it shou ld be noted that t h is prolon ge d period of high RGM begins several days prior to the TDF

test and also that there were seve ral episode s of even higher RGM (and GEM and HGP)

concentratio n s later in th e month, on 11/23 and 1 1 /26-27, lon g after the t e st burn had ended.

Figure 18 compares the time series of the rela tive CALPUFF modeled plume impa cts, the SO2

measureme n ts from the Clarkson G r oup, and th e RGM mea s urements f r om the ERG group at
the Shoreham North site. There are a number of coincident periods of modeled plume impact
and measured SO 2 (No v ember 5, 6, 7, 11, 15, 17, 21), most of whi c h also sho w elevated

concentratio n s of RGM. Note that many of th ese occur o n days outside the TDF test burn period, and would be consistent with small but perceptible contributions of SO 2 and RGM from the IP plant under its st andard (oil and wood waste) operating conditio n s. Note also that the relatively large RGM an d SO 2 spike on 11/23-2 4 , a period of strong northeasterly winds when no impact from the IP plant was predicted in Sh oreham.

Page 27 of 4 2Figure 18. Compariso n of Modeled IP Plume Impact, SO2 and RGM at Shoreham North

As noted previously, th e most likely conditions f o r IP plume impacts at the Shoreham North site occur during persistent southerly surface winds, which tend t o also coincide with synoptic-sca le transport winds from th e South an d Southwest. Figure 1 9 compares the Clarkson Shoreham
SO 2 data (expressed as hourly averages) with sim ilar measureme n ts from 4 rural sites in

northeaster n NY (Whiteface Mtn. Base, Paul Smith’s, Pise co Lake and Grafton State Park).

The Shoreham SO 2 spi k es are not locally uniqu e, but clearly coincide with periods o f high SO 2 at many surrounding rural sites indicative of regional transport, and ca n’t be attrib uted to local impacts from the IP source. The corres pond ence between modeled IP plume impacts an d
measured SO 2 at the Shoreham Nort h site, durin g the TDF test burn and during othe r periods of routine oper ation, appea rs to be coin cidental rath er than causal.

A similar argument can be ma de regarding causalit y of the peak Shoreham RGM

concentratio n s, which often coincided with periods of modeled IP plume impacts and/o r elevated Sh oreham SO 2 concentrat i ons, and which appear ed (Figure 16) to be (illogica lly) higher durin g the TDF test burn period. As sho w n in Figure 20, howeve r , RGM in Underhill, VT (50 miles north of Shore ham and no t likely influe nced by IP emissions) are 10 times higher than
RGM in Shoreham on t he (11/7/06) first day of the IP TDF test burn. The apparent Shoreha m RGM increase during th e TDF test burn is likely to be coincid ental rather than causal.

Page 28 of 4 2Figure 19. 11/06 SO2 Concentrati ons at Rural Sites in Shoreham, VT and Upstate NY

Figure 20. Reactive Gaseous Mercury Concentrations in Shoreham and Underhill, VT, 11/06

Page 29 of 4 2A possible e x planation for the much higher RGM concentrations in Underhill than in Shoreham is that RGM, originating primarily from distant coal burning and waste incineration sources, is highly reactive and rapidly depleted within the mixed surfa c e layer through deposition to the
earth’s surf ace. Air arriving at the low elevati on Shoreham site (abo ut 50 meters above sea level) is always within the mixed layer and has previously passed o v er higher surrounding terrain, where most of the RGM has bee n removed. Air arrivi ng at the 400 met e r Underhill sit e is often above the mixed la yer, especially during the colder months, and so may contai n RGM transported f r om distant

sources, w h ich has n o t yet been depleted through con t act with th e earth’s su rface. The estimated boundary layer depths (from NOAA
EDAS 40 Km grid model) for Underhill and
Shoreham on 11/6-8/06 are plotte d In Figure 21. On the (11/7) day of high R G M at both sites, t he 5 0 m Shoreham site was below the mixed layer all day, wh ile the 400 m Underhill

site was above the mixed layer for most of that day. Figure 21. Estimated boundary l a y e r depth s , Shoreham & Underhill , VT, Nov. 6-8, 2006

It can also be noted from Figures 20 and 18

that on the few occasions during 11/06 when
Shoreham RGM exce eded Underhill RGM (Nov. 4, 9, 10 and 24), t here were no CALPUFF modeled impacts from the IP source at the
Shoreham North site. So again, it s eems probable that the highest Sh oreham RGM

concentratio n s are asso ciated with regional tran sport rather than IP emi ssions durin g the TDF

test burn or under its ro utine oil and wood burning operatio ns. To the extent that some of the
observed RGM at Shoreham ma y have resulte d fr om IP emissions, th ose loca l im pacts appea r to be at le ast an orde r of magnitude lower t han those r e sulting fro m long range transport impacts at h i gher elevations in VT.

Figures 4, 1 2 , 19 and 2 0 also show higher reg i onal levels of PM 2.5 , SO 2 and RGM on 11/26 an d 27, 2006. NOAA HY-SPLIT back trajectories a rriving at Shoreham every 2 hours on t he 26 and

27 th are plot ted in Figur e 22. Altho ugh 11/26 and 27 were days when the CALPUFF mode l indicated p o tential imp a cts from the IP boiler (not burnin g TDF but rather its re gular mix of

residual oil and wood, it is likely that any perc eptible local source influences may have been masked by larger coin cident region al transport influen ces. As for the earlier 11/6- 8/06 event (Figure 14), the synoptic –scale flow s for the 11/26-27 event passed over high emission areas in the Midwestern US, and it is likely th at VT pollutant concentr a tions of SO2, RGM and other coalassociat ed trace elements on these dates were heavily influenced by regional transport – rather

than local e m issions.

Page 30 of 4 2

### Figure 22. HY-SPLIT Back Trajectories Arriving at Shoreham on 11/26 & 27, 2006

r g a n i c C o m p o u n d A n a l y s i s o f C l a r k s o n P U F S a m p l e s

a i l y P U F s a m p les (quartz filter with bac kup polyurethane foa m ) collected from 11/4/06

r o u g h 1 1 / 2 6 / 0 6 a t b o t h S h o r e h a m sites were analyzed by gas ch rom a tography at the Clarkson

A R E S L a b o r a t o r y (Cen ter for Air R e sources Engineering and Scienc e) for selected m i d-weight

l k a n e s ( C 1 9 t h r o u g h C 4 0 )

, P A H s ( p o l y c y c l i c arom atic hydrocarbons) and a few polar organic

o m pounds. Given the relatively lo w expected concentrations and hi gh cost of anal ysis, only the (pa r tic u late ) po rtio n of the s a mples wer e an alyzed, and m a ny of the s e were f i rst com posited

t o 1 0 m u lti-day sam p les for each s ite, in clud in g the November 2006 dates : 4-5, 6

, 7-9, 10, 11-

2

, 1 3

, 1 4

- 1 7

, 1 8

- 1 9

, 2 0

- 2 4

, 2 5

- 2 6

.

i g u r e s 2 3 a n d 2 4 s h o w t h e t e m p oral pa tte rn s of the total m easured Alkanes and the total

easured PAH com pounds for the Shoreham No rth and South sites during Novem b er, 2006. It

a n b e n o t e d that the a b solute conc entra tions a nd daily var i ations are q u ite sim ilar at the North

n d S o u t h s i t e s
, s u g g e s t i n g t h at the Alkanes and PAHs are not dom inated by a single local

u r c e l i k e I P t h a t w o u l d l i k e l y n o t i m pact bot h sites s i m u ltaneou sly. Nor are con centr ation s i g h e r o n t h e T D F t e s t b u r n d a y s t h a n on other sam p le days during the month.

i g u r e s 2 5 a n d 2 6 s h o w t h e a v e r a g e A l k a n e and PAH concentration profiles (m easured

t h e overlapping 5-day period when O

D

t h

C

A

c f ilter

i n 1

F

m

c

a

s o h

F

c o m pounds) for sa m p les collected during the 5 days of the TDF test burn (11/7, 11/8, 11/9, 11/10 and 11/13) com p ared to the aver age concentratio ns during a TDF was not burned (11/ 4, 11/5, 11/6, 11/11 and 11/12).

Page 31 of 4 2

### Figure 23. Time Series of Total Measu red Alkanes at Sh oreham Sites, Nov. 2006

Figure 24. Time Series of Total Meas ured PAHs at Shoreham Sites, Nov. 2006

Page 32 of 4 2

### T h e A l k a n e s a r e d e f i n e d b y c a r b o n n u m b er (C 19 through C40) and the PAHs defined by the

e c i f i c c o m p o u n d s i d e n t i f i e d

. T h e s e data are averaged for the Shoreham North and South sites.

h e a b s o l u t e c o n c e n t r a t i o n s a n d s p e c i e s p r o f iles for both the Alkane and PAH compounds are

e r y s i m ilar for the days of the TDF test burn compared to days when TDF was not burned, and

r s e v e r a l s p e c i e s a r e s l i g h t l y h i g h e r on days with no TDF com bustion. s p
T

v f

o Figure 25. Comparison of Alkane Profiles on TDF Burn Days and Non-Burn Days.

Figure 26. Comparison of PAH Profiles on TDF Burn Days and Non-Burn Days.

Page 33 of 4 2

### F o r e n i c sources like plant waxes are often associated w

num b ers especially in the C29 to C31 range. In this case, it can be noted from Figure 25 that there was a relatively greater abundance of even num bered carbon compounds in this range, suggesting contributions from anthropogenic com bustion sources. Several of the m easured PAHs (naphthalene, fluorine, phenanthrene, fluor anthrene and pyrene) are on Ver m ont’s list of

“hazardou s air con t am inants”. How e ver, th e m easur ed con c entrations were well below the lev e l

of the state’s hazardou s am bient ai r standard s in all cases, no r does there appear to have been an y perceptible contribution to the PAHs or Al kanes from the IP plant burning TDF fuel.

Several of the com posited f ilte r extr acts used f o r Alkane an d PAH analysis were a l so analyz ed for polar organic com p ounds. These included 3 sam p les for each site, covering the periods 11/4

- 5/06 (Pre Burn), 11-7-9 / 06 (TDF Test Burn), a nd 11/14-17/06 (Post Burn). As expected, all

sam p les exhibited a strong pres ence of levoglucisan, considered a direct tracer for wood

com bustion (including both residential wood burni ng and industrial sources). The levoglucisan peak is clearly eviden t in the F i gure 27 gas chrom a togra phs for the polar organic com pound analys is for all the sam p les from the Shoreham No rth site, as was also the case for the South site. t h e A l k a n e s
, w h i c h a r e g e n e r a l l y n o n

- r e a c t i v e and have minim a l biolog i c a l a c t i v i t y
, b i o g ith relatively high ratios of odd to even carbon

Figure 27. Chromatograms for Polar Organ ic Compounds at Shoreham North Site.

Page 34 of 4 2

### An addition a l (unexpe c t ed) peak was identif ied som e what unique ly in the Shoreham North

sam p le collected 11/7/9/06 during the TDF test burn for a com pound eluting at 28.60 m i nutes

. This peak was m u ch less pronounced in the other (pre-burn and post-burn) com posites, as well as

in the 11/7-9/06 sam p le from the South site (w here m odeled IP TDF source im pacts were m u c h

lower than the North s ite ). Using the NIST m a ss spectral library, this peak w a s ten t atively identified as azelaic acid (nonanedioic acid) sylyl derivative and has been subsequently

confirm e d as azelaic acid using a neat standard at the Clarkso n Laborato r y.

I t c a n b e n o t e d i n F i g u r e 2 8 t h a t w h i l e t h e w o o d smoke tracer levoglucisan is highest at both sites

t h e 1 1 / 4

- 5 / 0 6 p r e

- t e s t b u r n s a m p le, the Azelai c acid is uniquely highest at the North site

makes it extremel y ch allenging to discern the separate influence of the IP b o iler in the
Shoreham data. Of all the Shoreham measur ements, the DRUM dat a may provi de the best opportunity to discern some influence from IP – under sta ndard opera t ing conditio n s or during

the TDF test. Reasons include:

- DRUMs ran at both Shoreham sites f o r nearly the entire month of Nov.20 06,

- Highly resolved particle size in formation (8 sizes) to help distinguish coa r se mode and fine mode sources and aged vs. local very fine particles,

- Highly resolved tempo r al information (every 3 hours) provides best opportun i ty for discerning short-term impacts of a n earby source plume,

- Detailed ele m ental composition in cluding tracer s for wood (K), oil (Ni) and TDF (Zn). 

### i n (location of m a xi m u m modeled IP plum e i m p act) during the TDF t e st burn. One of the

prom inent industrial ap plications of azelaic acid is as a p l asticizer in t h e p r o d u c t i o n o f r u b b e r used in tire m a nufacturing, and so its large in crease in the air sam p les taken downwind of the TDF test burn suggests it m i ght be useful as a direct qualitative tracer for TDF fuel c o m bustion.

Figure 28. Levoglucisan and Azelaic Acid in S h oreham on TDF Bur n and Non- Burn Days.

Azelaic acid ?

DRU M Res u lts

The coincid ental occurr ence of a re gional transport event during the fir s t few days of the TDF test burn, and on several other occasions durin g the Nove mber 2006 i n tensive sampling period,

Page 35 of 4 2Figure 29 is based on data from the DRUM samples which have bee n aggregated up to dail y PM 2.5 (sum of data from the 6 smallest size bin s and eight 3-hr samples/day), and a v eraged fo r both Shoreham sites for the days of t he TDF test burn (11/7, 8, 9, 10, 13) and for all other days during the Nove mber 2006 sample period (11/2-6, 11, 12, 14-29). The shaded gray area in Figure 29 h i ghlights ele m ents for which the ratios (TDF Bur n days / No n-TDF days) are within +- 20% of 1:1. Nearly all of the e l e m ental ratios fall into t h is range, indicating re latively little increase (or decrease) on days of the TDF te st burn co mpared to other days. Exception s

c l u d e F e (marginally higher on T D F days), Ni (about 1. 5 times hig h e r i n

e o n T D F days) and

Particulate iron in the Shoreham DRUM sa mples o ccurs primarily in the larger particle size s

0 % o f F e i s > 1 m i c r on) and appears to be primarily from windblo w n soil, as it is highly

i

, A l a n d C a ( i n t h e l a r g e r s i z e r a n g e s )

. However, t he largest p r oportionat e

d a ys vs. other sa mple days. S is emitted by fossil fuel (and

p a rticle-phase

b u t w e a t h e r

, a n d s o w h i l e w e expect most

e x p source influen ce – for source s

s p e c i a l l y Z n ( a v e r a g i n g n e a r l y t w i c e a s h i g h o n TDF burn days).

Figure 29. Shoreham PM 2.5 Trace Elements on TDF Burn Da y s vs. other Sample Da y s

( 9
correlated w i t h S

increases in iron on TD F Burn Days occur in th e smallest p a rticle size r anges (twice as high on TDF burn days in the t w o smallest particle size bins). A slight increa se in very fine particle F e could potent ially result fr om the small amount s of steal belt re mnants in the TDF fuel.

It may be n o ted that sulfur and p o tassium are two elements which exhibit small difference s ( w i t h i n +

- 1 0 % ) o n T D F t e s t b u r n TDF) combustion sour ce s, but prima r ily as gase ous SO2, with a small fr a c t i o n a s sulfate aero s ol. Addit i o nal sulfate a e rosol is for m ed from o x idation of SO2 in the atmosphere,

t h i s s e c o n d a r y f o r m a t i o n t a k e s t i me, more s o i n c o l d secondary sulfate to be present in relatively small size ra nges (DRUM stages 5-8), we don’t

e c t S i n any particle size ran ge t o be a good indica tor of local burning oil o r TDF fuel.

Page 36 of 4 2Potassium, like levoglucisan, can be a good indi cator of wood combustion, but potassium is also presen t in soil dust and is relatively abun dant in smoke from fire works and in sea salt

aerosol. W e don’t expe ct fireworks influence in t he Novemb er 06 Shore ham data, and transport
of sea salt a s far inland as western VT is relatively rare. So il K will tend to occur pri m arily in the larger particle sizes (DRUM stages 1-4) and on that basis, can be distinguished from wood smoke K, which would t end to occur in smaller p a rticle sizes (DRUM stages 5-8).

Figure 30 shows the pa rticle size d i stributions f o r S (left) an d K ( r i g h t ) f r om the DRUM samples, aggregated for both Sh

a n l e difference d u ring the T D F test days compared to other sa mple days, and is foun d primarily in the smaller size range s (less than a bout 1 micron in diameter).

T D F t e s t

u r n a n d u n d e r s t a n d a rd operating condition s and might be expected to contrib u te to wood

Nove mber 2006 (grey bars). It can be noted th at the large s t oreham sites and avera ged for days during the TDF burn (black bars)

d f o r a l l other sample days (grey bars). As expected, the particu late sulfur s h o w s l i t t

Figure 30. Particle Size Distributions for S (left) and K (right) averaged for both Shoreham sites on day s of the T D F test burn and on other da y s d u ring November 2006

Potassium shows much higher concentrations in the largest size bin (lar ger than 5 microns in diameter) indicative of coarse mode particle s . T h is coar se K is likely ind i cative of local soil dust
emissions fr om sources like dirt ro ads or fres hly plowed fields, as very large particles are typically not transported over long distances. Th e K data also exhibit a bimodal size distribution

, with a secondary peak in the smaller (0.25 to 0.56 micron) size range . The IP source burns a

substantia l amount of wood waste (typically about 15 to 2 0 tons/hr) - both during t h e b

smoke and associated K in Shor eham. However, there are also many other smaller bu t numerous local and reg i onal wood b u rning sources contribut ing to wood smoke and f i ne particle

K concentra tions in Sho r eham. In any event, i t can be noted that there is no incr ease in the

smaller size d K particles during the TDF te st burn (nor was any increase expected).

In Figure 31, the DRUM data for Ni (left) and Zn (right) are averaged fo r each particle size b i n for both site s for samples collected during the T D F test bur n days (black bars) and for samples

collected du ring other d a ys during

Page 37 of 4 2a b s o l u t e a n d proportion ate increase s in both Ni and Zn occu r primarily in the 3 smallest particle

Nickel is oft en a good tracer for residual oil combustion and might be expected to in crease when the IP plume is impacting the Shoreham sites. It would a l so be expe cted to increase during

o n c e n t r a t i o n s, the cau s e for th is is unclear. Possibly t here is so mething about the TD F size bins – 0.56 to 0.34 μm, 0.34 to 0.25 μm, and 0.25 to 0

. 09 μm. This fine particle increase (especially in the smallest stage 7 and 8 size bins) is co nsistent with contributions from a relatively nearby source, as particles from more distant sour ces would t end to agglomerate into a slightly lar ger size ran ge.

F i g u r e 3 1

. P a r t i c l e S i z e D i s t r i b u t i o n s f o r N i ( l e f t ) a n d Z n ( r i g h t ) a v e r a g e d f o r b o t h Shoreham sites on day s of the T D F test burn and on other da y s d u ring November 2006

transport events from t he East Co ast Urban Corridor, which con t ain s a high d ensity of oil burning utilit y sources. However, there’s no logi cal reason t o expect Ni emissions fr om the IP
boiler to increase when TDF fuel is added. As with the apparent increase in RGM

c emissions t hat affected the efficie n cy of the flue gas control syst em, allowing increased

emissions o f chemical species like Ni and Hg t hat are not directly associated with the TDF fu el itself. Or possibly the a pparent incr ease in fine nickel on T D F burn days is – like t he increase s in SO 2 and RGM – larg ely coincide ntal and due more to a concurrent regional tra n sport event
than to influence from t he nearby I P plant. Th e large increases in the very smallest size ranges suggests th at at least some of the increase is d ue to nearb y , un-aged sources. Whatever th e cause, It sh ould be no t ed that the increase in PM 2.5 Ni - a v eraging about 0.3 ng/ m 3 higher o n TDF burn days - was ve ry small.

The absolut e and propo rtionate in creases in P M 2.5 Zn on TDF burn days were larger than fo r any other DRUM species, avera g ing about 5 ng/m 3 higher on TDF burn days. The large

r o p o r t i o n a t e increase in zinc in the smallest pa rticle size ra nges during the TDF test burn was p definitely an expected result, given the relative ly high Zn content of TDF fuel (e stimated as roughly 1% by mass of TDF fuel). This increa se in PM 2.5 Z n is also quite similar for the DRUM data (aggregated up to PM 2.5 size a nd 24-hour averaging times) and the Clarkson 24-hour PM 2.5 speciation filters (Figure 32).

Page 38 of 4 2Figure 33 shows the time series o f PM 2.5 Zn a t
the Shoreham north and south sites for

Nove mber 2006. The data for the two site s

m a g n i t u d e a n d t e m p o r a l t r Fig. 32. Average Shoreham PM 2.5 Z n , 1 1 / 0 6

e n d f o r most days, suggesting

i n i n data at th e 2 Shoreham sites were well correlated (R 2 = 0.78) on days during

Nove mber 2006 when TDF fuel was not burned, but poorly correlated (R 2 = 0.38) on days of the TDF test burn. In Figure 34, it can

be noted th at PM 2.5 Zn i s slightly higher on 11/8

at the north site and mu ch higher o n 11/9 at the

south site

. These results are co nsistent wit h
the CALPUFF modeled IP plu m e i m pacts displayed in Figure 5. The model results also

indicated likely IP plume impacts a t the north

site on 1 1 / 7 , although any perceptible lo cal
source effect on 11/6 or 7 th may well have been overwhelmed by the regional tra n sport event
indicated in Figures 4, 1 2 , 13, 14, 19 and 20. common, relatively distant source

f l u e n c e s on both sites. As previously

d i c a t e d i n Figure 11, the finer (Stage 7) Zn

Figure 33. Time series of PM 2.5 Zn at Shoreham North an d South Sites, Nov., 2006

Page 39 of 4 2A n a d d i t i o n al perspe c tive on local vs. more distant Zn so urces is pro v ided in the particle size

Z

m i c r o n s ; m i d s i z e = 1

. 15 to 0.56 microns and

t h a t t h e coarse and midsize Zn initially peak

r e g i o n a l t r a n s p o r t e v ent), but t hen decline

p a r t i c l e s are increasing (and when modeled

t a r e h i g h e s t

– f i r s t a t t h e n o r t h site on 11/7

r c o n t r a s t , another la rge Zn episode occur s

o n t h

– o n 1 1 / 2 3 a n d early on the 24 th

.

This second Zn event h ad the highest very fine Zn of any ti me outside the TDF burn period, but also had a much different particle size distribut ion – in which coarse particle Zn > midsize Zn > finest part i cle Zn. This is exactly th e opposite t o the patter n of fine>> midsize > coarse particle

Zn that occu rred during the days of TDF tire bur n influence. The dominance of very f i ne particle Zn during th e TDF test days is con s istent with influence fro m a near-by source. T he Zn size

distribution f o r the 11/23 -24 event is unusual, a s Zn is typica lly found in fine mode particles, and coarse mode particles - such as wind blown soil, re-entrain ed road dust, tire wear and fugitive
emissions fr om materials processin g sources - rarely emit particles less than abou t 1 micron diameter. So it appears that the Zn on 11/23/06 (Thanksgiving Day) originated from a variety of very differen t kinds of so urces.

As previously noted (Fig ure 17), the 11/23-24 event also resulted in the highest con c entration s of gaseous elemental, reactive gaseous and particle-ph ase mercury observed at Shoreham north during November 2006. As displayed in Figure 35 below (based on the stage 7 DRUM data plotted in Figure 3 4 . The S h o r e h a m D R U M different par ticle size ra n g e s ( c o a r s e = 1 0 t o 1

. 1 5 very fine = 0.56 to 0.09 microns). I t can be not e d
on 11/6 an d early on 11/7 (concu rrent with t h e throughout 11/7 n d a t a were aggregated for bo th site s and 3

th , 8 th and 9 th when the finest Z n impacts at the Shoreham sites during the TDF t e s and 8, and then at th e south site on 11/9. F o (concurrently at both Shoreham sites) later in th e m

F i g u r e 3 4

. T i m e S e r i e s o f S h o r e h a m Z i n c P a r t i c l e S i z e F r a c t i o n s , N o v e m b e r , 2 0 0 6

Page 40 of 4 2data for fine particles be tween 0.34 and 0.26 microns), the 11/23 event also includ ed a highly
unusual mixture of tra c e elements. In this case, the concentration s are normalized to a common Y-scale by dividing the individual 3-hr elemental concentrat i o n s b y t h e i r m o n t h l y

means.

Figure 35. Average Sh oreham Trace Metals from Stage 7 DRUMs (0. 26-0.34 microns)

Typically, V is a good tr acer for oil combustion (which tend s to come t o VT from the east coa s t urban corridor), As an d Cu are o ften tracers for smelter s (which ty pically com e from th e northwest of VT), Mn fo r steel prod uction or di esel exhaust (usually coming from the west or north of VT), and Fe for soil (often of more loc a l origin). Its highly unusual to see all of these metals plus Zn and Hg all present in relatively high concentrat i ons in VT at the same time.

Figure 36 shows the 11/23 NASA MODIS satellite image, surface wind vectors and synoptic

scale back t r ajectories f r om the NOAA HY-SPL IT model, run 48 hours back from Shoreham, starting at a height of 50 0 meters every 2 hours on 11/23/06.

The predominant regional weather feature on 11/ 23/06 was a strong extratropical cyclo n e ( nor’easter ) which had formed a fe w days earli er off the Southeastern US coast a nd traveled i n a northeast e rly directio n, bringing strong wind s and re cor d rainfalls t o the Mid- Atlantic and southern New England coast on 11/2 2 and 23. The winds later strengt hened to hurricane force

as the stor m mo ved p a s t M a r i t i

rd m e C a n a d a i n t o t h e N o r t h A t l a n t i c o n Nove mber 2 5 . In VT on

e 2 3 , the synoptic wi nds driven by strong, c ounterclockwise circulat ion around the top and t h back of the low pressure system, bro ught flows from an East-Northeasterly direction. The origin of pollutants associated with these northeasterly flows is unclear, but the unusual combination of particle sizes, chemical species a nd meteor ol ogical conditions sugge st possible contributions

Page 41 of 4 2from areas east and northeast of VT, as well as coastal lo cations furthe r south alon g the path of

the storm. These pollut ants were clearly not asso ciated wit h TDF or ot her emissio n s from the IP plant, an d the elevated Zn concentrations o n 11/23 are clearly of a very differe nt character

t h a n t h o s e o b served on 11/7-9/06 during the TDF test burn.

m e

, while perceptible, were F i g u r 2 3 / 0 6 e 3 6

. M O D I S I m a ge, Surface Winds & HY-SPLIT Ba c k T r a j e c t o r i e s f r o m S h o r e h a m , 1 1 /

T h e i n c r e a s e d c o n c e n t r a tion in azelaic acid, a compound employed in rubber pro duction, in samples collected durin g the TDF t e st burn suggests a small but perceptible inf l uence of the

test burn in Shoreham. The elevated Shoreham Zn concentrations, o n ly in the finest particle sizes, and specifica lly on days whe n IP source impacts were modeled at the Shoreham north (11/7-8) and south (11/9-10) sites re spectively, provide the clearest pollut ant measurement data that can reasonably be attributed to emissions associat ed with the TDF test burn. From Figure

4

, i f w e a s s u m e t h a t d i f f e r e n c e b e t w e e n t h e S h o r e h a m s i t e s d u r i n g p e r i o d s o f m o d e l e d p l u 3 impact durin g the TDF t e st is an in d i cator of the TDF impact, then the largest 3-ho ur PM 2.5 Zn signal from the test bur n was about 50 ng/m 3 observed from 6 to 9 AM on 11/9/06 at the
Shoreham south site. This corresponded to daily PM 2.5 Zn, average d over the 24 hours of

1 / 9 / 0 6

, o f 1 2 n g / m 3

. T hese increa sed concent rations of Shoreham Zn 1
well below t he levels of VT (or fed e ral) health standards - as were co ncentrations of all other measured metals (including Hg), PM 10 , PM 2.5 , SO 2 and measured organic co mpounds - throughout the month of Nove mber 2006, includ ing the days of the IP TDF test burn. Shoreham

concentratio n s of organ ic carbon, nickel and iro n al so incre a sed slightly during the t e st burn, but

these increa ses may wel l have been caused, at least in part, by a coincident region al transpor t event during the first few days of the test.

Page 42 of 4 2

## Appendix I

Trial Burn Field Observations/Site Reports

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3, South

802-241-3841



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: David Manning

Date: November 30, 2006

Subject: Site Visit & PM Testing at International Paper on 11/6/06

I made the following observations of the tire deri ved fuel (TDF) trial burn at International Paper (IP) in Ticonderoga, NY on Monday, November 6:

Today was spent with discussions of the upcoming TDF trial burn at IP and a walking tour of the boiler feed system, boiler control room, and boile r house roof area. These activities included one or more of the following i ndividuals, along with myself:

Jim Witkowski, Atlantic Region Manager, EHS On-site Management, IP Stephen Regan, Env. Performan ce Manager, IP Ticonderoga Donna Wadsworth, Communications Manager, IP Ticonderoga Amy Dostie, Environmental Engineer, IP Ticonderoga Heather Perry, Process E ngineer, IP Ticonderoga various IP Ticonderoga bo iler and process operators Terry Grave, TDF Consultant

Marcus Kantz, USEPA Region 2 Alan Hicks, USEPA Region 1 Doug Elliott, Vermont APCD

IP personnel explained that they were hoping to di scover if TDF would help with start-ups, shutdowns, and load swings on the power boiler. Becaus e the recovery boiler must run “steady-state” the power boiler is left absorbing most of the cha nges in steam load. Their experience at other IP facilities indicated that burning TDF would help control irregularities in the combustion of wet bark, and also help prevent clumping of bark in the feed system.

IP Ticonderoga handles bark fuel using a pneumatic transport system. TDF, and in particular, the loose wires that accompany the tire chunks, may be difficult to handle in a pneumatic feed system because the wires would jam rotary seal s and may damage other components. Mr. Grave, IP’s TDF consultant, indicated that he looked at several TDF suppliers and tried to select the

### Site Visit & PM Testing at In terna tio nal Paper

supplier who could provide fuel with the least am ount of loos e wire. If T D F burning becom e s

perm anent, IP m a y consider a different fuel f eed system to avoid potential problem s. A s m all

am ount of TDF was collected by Do ug Ellio tt an d brought back to the VT APCD office.

We spent a few m i nutes observing the handling of bark and TDF in the storage area. Bark and TDF is piled on the grou nd in open s t ockpiles un til m oved by a f r ont-end loader into m e tering bins. Screw augers under the bins are powered by va riable speed drives, whic h control the rate at which bark and TDF is delivered to the pneum atic transport system . Mr. W itkowski s a id that the

am perage of the m o tors can be checked, and this is how the fuel feed rate is m onitored. Just prior

to the en tran ce to th e pne um atic sys t e m there is a belt conveyor that com b ines bark an d TDF

delivered from the two m e tering bins. During the em issions testing program IP intends to take

sam p les from this conveyor to verify the bark and TDF feed rates.

We briefly looked at the boiler controls, gages, and television m onitors. In addition to the

com puterize d boile r controls, th ere is a tele vision cam era showing fu el burning on the boiler grate. Unfortunately, the view does not show m u c h detail. W h ile in the boiler room I asked about soot blowing schedule and how the grates are cleaned. Boiler room personnel confirm e d that soot blowing is autom a tic and relatively continu ous. They also indicated that grates are em ptied

occasion a lly by sim p ly allowing th em to open downward. Ash then fall into a wate r-filled quench pit. A conveyor belt carries the wet ash from the bottom of the pit to a disposal area.

I asked how soot blowing and gr ate cleaning would be inco r porated into the te sting p r otoco l

. Because the soot-blow is autom a tic and one of the four banks blows every 45 m i nutes, it did no t appear that any special test cons iderations were needed for this event; a soot blow would occur at least once during alm o st every test run. But th e grate dum ping only occurred two or three tim es per day. It appeared that this had not been consid ered in the test plan. I pointed out that in m a ny test program s a special test run is perf orm e d sp ecifically incorporating a grate cleaning to see

what the em issions are d u ring th ese events. Mr. W itkowski s a id that this would be discussed with the NY DEC representative pr io r to beginning the full stack test program

.

We also briefly discussed the operation of the we t scrubber. T h is is a custom -built device uniqu e to IP Ticonderoga. Mr. W itkowski s a id that he w ould get together with IP staff and have one of their engineers put together a presentation for us describing the scrubbe r and it’s operation (see 11/14 trip report).

IP personnel said that they in tended to start by perform i ng pr elim inary particulate m a tter (USEPA Me thod 5) testing at several TDF feed r a tes. W h en they had found the m a ximum TDF feed rate that appeared acceptab l e, th e for m al compliance tes ting (includ i ng m e tals an d other

toxic em issions) would begin at th at rate. They anticipated th at the com p l i ance testing would not begin until late in the week, or, m o re likely, the beginning of next week.

dm



### Testing on 11/6/06 Page 2 of 2

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3 South

802-241-3840



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: Doug Elliott

Date:

Subject: International Paper Trial Burn - Field Report for Monday, November 6, 2006

Field Report for 11/06/2006. See also Da ve Manning’s field report for same day.

Weather: partly sunny most of day; mild with temps 30’s to 40’s; winds light but steady from the South all day as evidenced by Power Boiler plume.

Dave Manning and I arrived at the facility at approximately 8:30 am on Monday November 6, 2006. All visitors are required to sign in and out at the security center upon entering or leaving the plant property and must always be escort ed around the plant by IP personnel. First time visitors are also required by International Paper to view two safety videos on potential hazards at the facility. After signing in and viewing the sa fety videos we were escorted to a conference room that was reserved for VT APCD, U.S. EPA and NYDEC personnel for the duration of the

trial burn.

The day began with general intr oductions of the on-site IP and regulatory personnel. IP personnel were represented by: Jim Witkowski, IP Regional EHS Ma nager, Atlantic Region (Camden, SC) Donna Wadsworth, IP Communicat ions Manager (IP Ticonderoga) Stephen Regan, IP Environmental Pe rformance Manager, (IP Ticonderoga) Amy Dostie, IP Environmental Engineer (IP Ticonderoga) Heather Perry, IP Proces s Engineer (IP Ticonderoga) Terry Gray, President T.A.G., Tire De rived Fuel Consultant (Houston, TX) The following state and federal regulat ory personnel were on site today: Dave Manning, VT APCD Doug Elliott, VT APCD Alan Hicks, U.S. EPA Region 1 (Chelmsford, MA) Marcus Kantz, U.S. EPA Region 2 (Edison, NJ) Chad Siever’s, NYDEC

### Site Visit & PM Testing at In terna tio nal Paper

The plan for the day was:

1. Following our viewing of the safety videos a nd introductions, we were expected to tour

the bark feed and TDF feed areas an d then proceed to the Power Bo iler control room and

then to the Continuous Em issions Monitors (C EMs) room on the roof of the Power Boiler building where the stack testing would be conducted.

2. IP intended to commence baseline testing f o r par t iculate m a tter to de term ine exis ting

em ission levels without any TDF. Te sting wa s to consist of thr ee individual Method 5 particulate test runs.

3. If baseline testing were to have proceeded on schedule, IP could have considered adding the first TDF to the boiler on this day. Howe ver, as discussed below, baseline testing was delayed due to problem s with the bark feed system and IP never began adding T D F

until Tue s da y at approx im ately 8:15 AM.

Following our introductions we proceeded to the wood yard. At the wood yard a pile of TDF was on-site ready for the trial, however this was only a portion of what would be needed for the trial and IP expected to require seve ral m o re loa d s as the tr ia l proceeded. Mr. Gray discussed the TDF processing operations and p u lled s a m p le pi eces from the pile that dem onstrated certain aspects of th e process i ng . The TDF for the tria l was being supplied by a com p any in the Buffalo,

NY area. I collected s e veral p i eces that showed various ch aract e r is tics b u t did not co llec t a representative sam p le at that tim e. Most of the pieces in the p ile were less than 1 to 1.5 inches square. The pile con t ain e d little to n o “bead” wire ; the thick cord wire e m bedded in the tire bead area. It was explain e d th at th is thicker wire would cause operati onal problem s with the rotary air lock pneumatic feed system and had to be essent ially elim inated. It was not clear whether this would be a problem with the m o re perm anent TDF feed system that would be erected should IP pursue long term use of TDF.

Som e of the TDF pieces still con t ain e d substan t ia l am ounts of tread wire; sm all strand s of wire

that cris s-cross the tread area of the tire. It was evident on so m e pieces of tread that th e tread wire had been ripped ou t by the processing but m a ny pieces s t ill con t ained som e of this wire. The sidewall pieces contained no wire but had va rious types of rayon fiber cords. Failure to

rem ove at least som e of the tread wire has been reported as a problem fo r som e facilities burning TDF in that it will bridge the boiler grates and prevent air fro m getting up through and ash from falling down through the grates. W i thout com p aring this pile of TDF to that where no wire is

attem p ted to be rem oved I was not able to estim ate the percent of wire removal.

Near the TD F pile was a large hopper with a pair of screw augers in the bottom that dumped to a second screw auger leading to the existing bark f u el rotary air lock for pneum a tic conveying to the Power Boiler fuel surge bin. The wood yard is also where the logs ar e stored in piles and sent to the debarking and chipping operations building. The bark is used as fuel for the boiler, the chips are processed into pulp for paperm aki ng. The bark from the debarking operation (200 tpd) is supplem ented with excess bark or wood fu el from the wood yard via a front end loader (225 tpd). B a rk accum u lates in the w ood yard during tim es th e Power Boiler operates without wood fuel such as during breakdowns in the ba rk feed system. IP is allowed to burn 547

volum etric tons of wood/bark per day but instead attem p ts to feed a consistent 425 tons per day of wood/bark (17.7 tons per hour, around the clock). This w a s the wood fuel target rate during

Page 2 of 4

### Site Visit & PM Testing at In terna tio nal Paper

the trial. The com b ined fresh bark and wood yard bark fuel is dropped into a rotary air lock and

pneum atically conveyed to the Power Boiler’s soli d fuel surge bin where it is m e tered into the boiler. Following debarking the logs are sent to the chipp e r and the ch ip s sent e ithe r to the pu lp

m ill or to ou tside pu lp ch ip stor age piles ( t his is o f no direct r e levanc e to the Power Boile r operation).

The plan during the TDF trial is to maintain wood/bark fuel f i ring ra te at 425 tpd and add successively larger am ounts of TDF a s fuel oil firing is reduced. The augers in the T D F hopper

were calibrated such that certain settings on the screw drive cont roller would yield a set am ount of TDF per hour.

After viewin g the wood yard and debarking operati ons we proceeded to the Power Boiler control

room . The Power Boile r is a m u lti f u el boiler th at prov ides s t eam f

o r a 40 MW electr ic

generator an d for the m ill operations. The boile r is rated at 8 55 m illion B T Us per hour heat input but g e nerally runs well below this lev e l. G e nerally th e boile r is run with 177 m illion BTUs per hour com i ng from wood fuel when fire d at 425 tpd (17.7 tph) and the remainder from No. 6 oil. While IP has approval f o r prim ary a nd secondary sludge, digester knots, and waste oil they typically do not burn these. Since the Reco very Boiler is tied to the pulping processes it must run at a constant rate, ther efore the Power Boiler is us ed as the swing boile r, cutting f u el oil firing when steam de m a nd drops. Both boilers provide steam to a common steam header.

The Power Boiler control room contains the CE M readouts which the bo iler operators use to adjust the bo ile r. The co ntrol room a l so contains video im ages of the bark surge bin and the inside of the boiler overlooking the solid fuel gr ates. W ood firing was temporarily of fline for most of Monday m o rning due to a problem with th e bark feed system . While we were in the

control room the wood fuel had been restarted which was evident from the fuel feed m e ter
readouts as well as the video im age of the inside of the boiler which showed sparks and flam ing pieces of wood fuel flying around in the turbu l ence insid e the boiler. There was som e discussion of ensuring soot blowing was re presented in the stack testing as well as grate dum ping. Soot blowing is done autom a tically every 45 m i nutes fo r a portion of the boiler tubes with each tube eventually cleaned each 8 hours and therefore so ot blowing woul d be represented in each one hour particulate test. The boiler grates are no rm a lly dum ped once per 8 hour shift. It was requested th at at leas t on e of the three success i ve particulate m a tter tests include a g r ate dum p cycle. For grate dum ping, wood fuel feed and underf ire air is shutoff and the grates dump (like a trap door) to drop accum u lated ash to the bottom of the boiler where it can be rem oved. The grate dum p process takes approxi m a tely 10-20 minutes (? ).

After viewin g the control room we proceeded to the roof where the CE Ms are lo cated and the stack testers were commencing th e first of thre e particulate m a tter Method 5 runs. Below are readings I had taken from the readout screens du ring the particulate testing. These values are

sim p ly observations at a point in tim e during the testing and can not be assum e d to represent the entire period, nor are the data va lues quality assured or pres en ted in the av er aging periods of the

perm it. The actual hourly averages for these pa ram e ters are reported on the printouts provided by IP for each day of operation during the trial.

Page 3 of 4

### Site Visit & PM Testing at In terna tio nal Paper

Due to problem s with the bark feed earlier in the day, the baseline pa rticulate Method 5 runs were not completed until late in the day. IP d ecided not to begin TDF fi ring until the next day.

Parameter Units 11/6 3:30 pm 11/6 6:00 pm

Oil fir i ng r a te gpm 42 42

Bark/TDF fir i ng rate t ons/day equivalent 425 426

T e m p D e g r e e C ?

- - - -

SO 2 lbs/hr 252 260

SO 2 p p m 1 8 0

- -

H 2 O % 1 7

. 1 1 7

. 4

N O x L b s / m m b t u 0

. 1 9 0

. 1 9

N O x p p m 1 1 2 1 1 2

O 2 % dr y 7.0 7.1

Pre scrubber opacity % 64.7 55.8

Steam flow 1000 lbs/hr 412 415

C O p p m 3 2

. 7 2 7



### Page 4 of 4

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3 South

802-241-3840



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: Doug Elliott

Date:

Subject: International Paper Trial Burn - Field Report for Tuesday, November 7, 2006

Field Report for 11/07/2006.

Weather: more clouds than sun; continued mild with temps 30’s to 40’s; winds still light and consistently from the South all day.

The plan for the day was:

1. Review of baseline stack particul ate Method 5 testing from Monday.

2. Commence TDF firing at 0.5 tph and monitor boiler response.

3. Proceed to 1.0 tph TDF firing if all looks fa vorable and again monitor boiler response.

The results from the three baseline part iculate testing runs were reported as:

Run 1 0.038 lbs/mmbtu

Run 2 0.040 lbs/mmbtu

Run 3 0.051 lbs/mmbtu Average 0.043 lbs/mmbtu

These are very respectable emission rates for th is boiler which is limited by its permit to 0.10 lbs/mmbtu. Prior stack testing ha s shown actual emissions to be in the 0.06 - 0.08 range. It will likely be difficult for TDF not to show some increase above this baseline level.

At 7:00 AM the boiler grates were dumped. At approximately 8:15 AM the TDF feed system was turned on, delivering TDF to the wood fuel ro tary air lock in the wood yard where it is

blended with the wood bark fuel and immediatel y blown to the boiler surge bin. If the boiler surge bin was full at that time it would take ap proximately one hour before it would reach the boiler as there is approximately one hour of solid fuel firing capacity in the surge bin at. As the TDF feed system is turned in the wood yard the so lid fuel feed auger in the surge bin is increased accordingly to account for the increased 0.5 tph TD F feed rate and the oil firing is cut back accordingly to ensure consistent heat input to the bo iler. Otherwise if the so lid fuel feed auger is

### Site Visit & PM Testing at In terna tio nal Paper

not increased, the solid fuel firi ng rate into the bo ile r rem a ins th e sam e on a volum etric basis and wood fuel ends up being displaced b y TDF. Th e purpose of the trial was to displace f u el oil usage. The solid fuel firing rate is m onitore d and recorded. This m onitor records solid fuel

volum etric federate, not actual heat input which must be calculate d based on the heating value of

the fuel. Since the wood fuel feed rate to the surge bin is being held steady at 425 tpd equivalent,

when TDF i f feed at a 0.5 tph feed rate in the wood yard (12 tpd equivale nt) the solid fuel feed auger in the surge bin m u st be increased to 437 tpd equivalent to ensure the boiler is firing 425 tpd wood and 12 tpd TDF (0.5 tph).

At approxim a tely 8:55 AM TDF was assum e d to be entering the boiler and being burned. At the 0.5 tph T D F feed rate I could not discern a dif f

erence in the vi deo im age of the inside of the

boiler verses no TDF. I record ed a set of reading from the CEM readouts at this point.

At approxim a tely 10:45 AM the TDF feed rate in the wood yard was increased to 1.0 tph and the surge bin auger was increased from 437 to 449 tpd equivalent and oil was cut back. W h ile steam

dem a nd from the boiler varies from m i nute to m i nut e the solid f u el rate is m a intained steady and oil is used to swing the load by increasing or d ecreasing as n ecessary. I recorded ano t her set of CEM readings during the 1 tph TDF feed rate. A g ain, the hourly average data was provided by IP the following day. The boiler operators conti nued to m o nitor and adju st the boiler at the 1.0 tph TDF fee d rate throughout the afternoon on Tuesday.

During the feeding of TDF we again visited the wood yard and the TDF feed system . From the wood yard one is able to view the TDF and bark fuel dropping into the rotary air lock. The

am ount of TDF entering the air lock appeared to be visibly very litt le and we requested to see the

calibration data. After som e discussion, we reques ted IP conduct a verifi cation of the TDF feed

rate. The ca libr a tion che c k was completed th e following day on W e dnesday and confirm e d the accuracy of the TDF feed rate.

At approxim a tely 7:00 P M the TDF feed was s hut off in the wood yard and the boiler was

returned to norm al operation. By 8:00 PM TDF was assum e d to be cleared from the surge bin and no longer entering the boiler. IP expected to resum e at the 1.0 tph T D F feed W e dnesday morning.

CEMs readout data taken during 0.5 and 1.0 TDF feed on following page. Again it m u st be

noted that th ese are prelim inary process control d a ta and are only a point in tim e. The boiler was being adjusted all day and the va lues varied from m i nute to m i nut e. The actual hou rly average data was provided by IP the following day.

Page 2 of 3

### Site Visit & PM Testing at In terna tio nal Paper

Parameter Units 11/7 0.5 tph 11/7 1.0 tph

Oil fir i ng r a te gpm 40.8 37.2

Bark/TDF fir i ng rate t ons/day equivalent 437 448.7

T e m p D e g r e e C ? 1 3 5 1 3 5

. 9

SO 2 lbs/hr 231 269.7

SO 2 p p m 1 7 8 2 0 9

. 7

H 2 O % 1 7

. 3 1 7

. 5

N O x L b s / m m b t u 0

. 1 9 0

. 2 0

N O x p p m 1 1 3 1 1 7

. 7

O 2 % dr y 7.3 7.5

Pre scrubber opacity % 55 61.7

Steam flow 1000 lbs/hr 393 387

C O p p m 3 0

. 8 3 5

. 7



### Page 3 of 3

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3, South

802-241-3840



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: Steven Snook

Date: November 17, 2006

Subject: Site Visit & PM Testing at International Paper

Field Report for 11/8/2006.

The plan for the day was:

1. For the boiler operators to continue to ga in experience controlli ng the boiler’s operation with TDF feeding at a rate of 1 ton/hr. The control/distribution of combustion air is believed to be one of the parameters that ne ed to be adjusted to ensure good combustion with this blend of fuels (oil, wood waste and TDF).

2. Validate the method that they use to control the TDF feed rate.

3. Have the vendor check the prescrubber opacity monitor. One of the process changes that has been noted is that the pr escubber opacity is higher when burning TDF. They want to make sure that the opacity sensor is operating correctly.

At 5:15 am the TDF feed system was started at a 0.5 ton/hour feed rate. At 6:00 am, the feed

rate was increased to 1.0 ton/hour.

The TDF feed system consists of a nominal 20 cubic yard hopper equipped with a pair of

inclined feed screws located at the bottom of th e hopper. The feed screw operate in parallel and work together to draw the TDF out of the bottom of the hopper. The RPM of these feed screws

dictate the TDF feed rate and is controlled with a variable frequency driv e (VFD). The VFD is controlled between 0 and 50 Hz output. Internati onal Paper has establishe d the calibration curve for this auger feed system and set the output at 12.56 Hz for a 1 tph feed rate. The feed augers discharge into a constant speed a uger that transfers the TDF into the solid fuel delivery system where it is mixed with the wood waste and pneuma tically conveyed to a f eed bin in the boiler

house.

At approximately 10:20 am, the TDF feed rate was validated: While operating the VFD at a 12.56 Hz output, they diverted the flow of TDF from the constant speed transfer auger to a preweighed collection box and filled the box to approxi mately 90% full. The time to fill the box was recorded and the full box was weighed: 580 lbs of TDF was collected in 16.5 minutes, for a

### Site Visit & PM Testing at In terna tio nal Paper

Page 2 of 2 rate of 1.05 tons/hour. T h is was considered to be sufficiently accurate and representative of a ‘1

ton/hr’ feed rate.

International Paper decided to wait one m o re day before conducting the P M testing at the 1 tph

TDF feed rate.

The 1 tph TDF feed rate was m a intain ed throughout the rest of the day.

Other regu la tory agen cy repr esentatives on site today: Michael Sundberg – NY DEC Marcus Kantz, USEPA Region 2 Alan Hicks, USEPA Reg i on 1

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3, South

802-241-3840



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: Steven Snook

Date: November 17, 2006

Subject: Site Visit & PM Testing at International Paper

Field Report for 11/9/2006.

The plan for the day was:

1. Shut down of the solid fuel feed system (w ood waste and TDF) from approximately 2:00

– 4:00 am for routine maintenan ce in the wood chipping operation.

2. At a 1 tph TDF feed rate, run the series of three 1 hour PM stack tests to be conducted following EPA Method 5. This is to determine if the PM emission rate is in compliance with the permit limits and to help assess if a higher TDF feed rate can be evaluated.

After the wood chipping system’s maintenance wa s completed, the TDF feed rate was turned on at 0.5 tph at 4:30 am. By 5:00 am, the TDF feed sy stem was back up to a 1.0 ton/hour feed rate.

The first PM stack test run was done from a pproximately 9:15 am to 10:15 am. During this sampling run, the CEM system indicated that the NO X 

### and SO 2 

### emissions were within permit limits. The preliminary result was 0.089 lb/MMBtu for PM emissions.

The second PM stack test run was done from a pproximately 11:10 am to 12:10 pm. During this sampling run, the CEM system indicated that the NO X 

### and SO 2 

### emissions were within permit limits. The preliminary result was 0.082 lb/MMBtu for PM emissions.

Since the preliminary PM emission rates were hi gher than expected, Inte rnational Paper decided to shut off the TDF feed at 4:00 pm.

Other regulatory agency repr esentatives on site today: Michael Sundberg – NY DEC Marcus Kantz, USEPA Region 2 Alan Hicks, USEPA Region 1 Doug Elliott, VT DEC

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3 South

802-241-3840



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: Doug Elliott

Date:

Subject: International Paper Trial Burn - Field Report for Friday, November 10, 2006

Field Report for 11/10/2006.

Weather: mostly sunny with patchy clouds most of day; still mild with temps 30’s to 40’s+; winds light but steady and consistently from a no rtherly direction all day as evidenced by Power Boiler plume going right over our heads on roof...the saturated plume actually resulted in light precip falling on us...each drop contained visible bl ack particles that resulted in black dots on

our hard hats when it dried.

The plan for the day was:

1. Review/discussion of 1.0 tph TDF stack partic ulate Method 5 testing from Thursday.

2. Commence TDF firing at 0.5 tph and c onduct PM testing at that level.

The results from the two 1.0 tph TDF particulate te sting runs from Thursday were reported as:

Preliminary Refined

Run 1 0.089 lbs/mmbtu 0.109 lbs/mmbtu

Run 2 0.082 lbs/mmbtu 0.093 lbs/mmbtu

Based on the preliminary results IP obtaine d Thursday afternoon, TD F was shut off at approximately 4:00 PM on Thursday and did not commence again until Friday morning at 0.5 tph at approximately 5:00 AM. It should be noted that a Method 5 particulate test consists of that portion of particulates captu red on the filter and weighed as we ll as the particulates that are captured in the sampling probe. At the end of each run, the probe is washed clean with acetone and placed in an oven (often overnight) to bake off the acetone so the remaining particulate can be weighed. The preliminary resu lts include only the material captured on the filter since the probe wash weight is not available until the next day. The filter weight also changes over time and a final weight is not determined until succes sive readings are with in a certain range of agreement. To express the emissions in units of lbs/mmbtu also requires pr ocess data that is not

### Site Visit & PM Testing at In terna tio nal Paper

f i nal until it has been r e v i ewed f o r ac curacy. Thu s f i nal resu lts are of ten n o t available until we ll after the testing.

At approxim a tely 5:00 AM Friday morning the TDF feed was turned on at 0.5 tph. The first particulate test at this level was started at approxim ately 11:00 AM. The prelim inary results (filter only ) were reported as 0.077 lb s/mmbtu. Th e second p a rticulate tes t run was started at approxim a tely 3:45 PM. The prelim i n ary results from this run were 0.083 lbs/mm btu. At approxim a tely 5:30 PM IP ceased TDF feed to the boiler for th e weekend. IP intend ed to explore options for reducing em issions over th e weekend, including ways to optim ize the wet scrubber, before recomm encing TDF fi ring on Monday m o rning November 13.

CEMs readout data taken during the 0.5 tph TDF f eed. Again it m u st be noted that these are prelim inary process control data and are only a point in tim e. Th e actual hourly average data for the entire day was later provided by IP.

Parameter Units 11/10

11:00am 11/10

11:37 11/10

11:53 11/10

12:02 11/10

12:21 11/10

3:07 11/10

3:55 11/10

4:21

Oil fir i ng r a te gpm 40.3 43. 5 4 2

. 9 4 3

. 3 4 1

. 0 3 7

. 6 3 8

. 5 4 1

. 8

Bark/TDF firing r a te tons/day equivalent 4 3 7

. 1 4 3 7

. 1 437.1 437.1 437.1 437.1 437.1 437.1

T e m p D e g r e e C ? 1 3 6

. 3 1 3 6

. 1 1 3 5

. 9 1 3 6

. 5 1 3 7

. 2 1 3 4

. 6 1 3 6

. 6 1 3 5

. 8

SO 2 lbs/hr 265.3 246.0 266. 5 1 7 9

. 0 3 0 9

. 6 2 8 4

. 0 2 5 3

. 5 2 3 2

. 5

SO 2 p p m 2 0 6

. 1 1 7 4

. 0 2 1 0

. 6 1 3 9

. 0 2 4 1

. 9 2 0 7

. 0 1 7 0

. 9 1 5 6

. 9

H 2 O % 1 7

. 5 1 7

. 6 1 7

. 6 17. 8 1 8

. 1 1 6

. 8 1 7

. 8 1 7

. 4

N O x L b s / m m b t u 0

. 2 1 0

. 2 2 0. 2 2 0

. 2 1 0

. 2 1 0

. 2 2 0

. 2 5 0

. 2 3

N O x p p m 1 3 0

. 8 1 3 6

. 9 1 3 7

. 3 1 3 2

. 8 1 3 1

. 9 1 1 8

. 2 1 3 3

. 3 1 2 5

. 9

O 2 % dr y 6

. 5 6

. 8 6

. 7 6

. 3 6

. 5 8

. 4 8

. 3 8

. 4

Pre scrubber

opa c ity % 6 6

. 5 6 9

. 6 6 4

. 8 6 7

. 0 6 8

. 3 6 7

. 4 8 1

. 2 7 5

. 1

Steam flow 1000 lbs/hr 413.8 426. 5 4 0 5

. 8 4 1 6

. 8 4 1 4

. 0 3 7 8

. 7 4 1 8

. 3 4 1 7

. 6

C O p p m 2 4

. 0 2 7

. 6 2 5

. 0 2 1

. 7 2 3

. 7 5 0

. 4 7 5

. 7 6 3

. 8

H e a t i n p u t M M b t u / h r 5 5 3 5 6 3 5 5 3 5 4 7 5 5 0 5 3 3 5 3 6 5 5 4



### Page 2 of 2

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3, South

802-241-3841



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: David Manning

Date: November 30, 2006

Subject: Site Visit & PM Testing at International Paper on 11/13/06

I made the following observations of the tire deri ved fuel (TDF) trial burn at International Paper (IP) in Ticonderoga, NY, on Monday, November 13:

IP had hoped to begin the formal compliance tes ting this week. Due to problems in finding an acceptable TDF feed rate, however, IP was stil l doing preliminary, particulate matter only, testing. Today’s test observation involved princi pally the following management and regulatory personnel (as well as myself):

Jim Witkowski, Atlantic Region Manager, EHS On-site Management, IP Donna Wadsworth, Communications Manager, IP Ticonderoga Amy Dostie, Environmental Engineer, IP Ticonderoga Heather Perry, Process E ngineer, IP Ticonderoga various IP Ticonderoga boiler operators Jim Canora, and other TRC Corp. testing personnel

Mark Winter, USEPA Region 2 Alan Hicks, USEPA Region 1 Michael Sundberg, Projec t Engineer, NY State DEC

Mr. Witkowski and Ms. Wadsorth said that TD F was not burned over the weekend, so we spent most of the morning waiting for TDF burning to begin and the boiler to reach steady-state conditions. The TDF feed rate for today was 1⁄4 ton per hour. Mr. Witkowski indicated that preliminary results from testing on 1 and 1⁄2 ton of TDF per hour (on the previous Thursday and Friday) were not encouraging. Particulate matter emissions appeared to be in compliance with their permit, but only just. IP pe rsonnel hoped that today would be the last of the preliminary testing, and that the full test ing program would begin tomorro w (November 14th). Mr. Sundberg of the NY State DEC said he would provide audit samples once the full testing had begun.

### Site Visit & PM Testing at In terna tio nal Paper

The prelim i n ary particulate test runs began in early afternoon at a TDF feed rate of 1⁄4 ton per hour. According to process m onitoring instrum e nts on the control panels, fi ve fuel oil burners were in operation at 53 gallons pe r minute, the bark feed rate wa s about 18 tons per hour. IP personnel compiled hourly averages of a variety of process data, a nd I obtained copies of these reports for Nove m b er 10 (last Friday) and 13 (toda y), which are included in th is trip report package.

After com p l e tion of the first test run there was a long delay while prelim i n ary results (essentially a rough filter weight) were obt ained. While waiting, we visited the boiler control room and

confirm e d that IP personnel cons idered the boiler operation norm al.

Prelim inary results ind i c a ted th e f ilte rweight m a y have been less than was noted during testing last Thursday and Friday. A rough, prelim inar y em issions estim a te of around 0.07 lb/MMBtu

was m a de by the test consultant. In m a king this estim ate it w a s assum e d that the p r ob e wash weight was the sam e as in previous testing. Th e visual appearance of the probe wash was not conclusive in this regard, but the assum p tion was questionable. IP personnel decided to have two more test runs perform e d at 1⁄4 ton T D F per hour to confirm these initial prelim inary results.

The particulate sam p ling system failed a leak check on the third run, so these results w e re discarded and a substitute (four th) test run was perform e d. IP personnel said that they stopped

f

eeding TDF to the boiler at the end of this te st run (approxim a tely 10:00 p.m

. ) Testing was not expected to resum e until the m i ddle of the ne xt day (Novem b er 14th). There was m a intenance scheduled on one of the paper m achines early the next m o rning, and steam dem a nd dur ing that period would not be sufficient to a llo w boiler em ission te sting

.

dm



### Testing on 11/13/06 Page 2 of 2

### Agency of Natural Resources
Department of Enviro nmental Conservation



### Air Pollution Control Division
Building 3, South

802-241-3841



### MEMORANDUM

To: Jeffrey Wennberg, Commissioner

Thru: Richard Valentinetti, Director

From: David Manning

Date: November 30, 2006

Subject: Site Visit & PM Testing at International Paper on 11/14/06

I made the following observations of the tire deri ved fuel (TDF) trial burn at International Paper (IP) in Ticonderoga, NY, on Tuesday, November 14:

Due to problems in finding an acceptable TDF feed rate, IP was still doing preliminary, particulate matter only, testing. Today’s site visit involved the following management and regulatory personnel (as well as myself):

Jim Witkowski, Atlantic Region Manager, EHS On-site Management, IP Donna Wadsworth, Communications Manager, IP Ticonderoga Amy Dostie, Environmental Engineer, IP Ticonderoga Heather Perry, Process E ngineer, IP Ticonderoga various IP Ticonderoga boiler operators and other personnel

Mark Winter, USEPA Region 2 Alan Hicks, USEPA Region 1

As was noted in my site visit report from ye sterday, 11/13, we were wa iting for more refined emissions results from three particulate matter te st runs performed that day. Also, one of the paper machines was shut down for previously scheduled maintenance and, until restarted, the

steam demand on the boiler would be too low to allow testing. While waiting, we received a detailed briefing on the operation of the power boiler’s wet scrubber emission control device by IP personnel.

IP engineers said the scrubber was manufactured by Entoliter and is considered a “vortex”

scrubber. It is a customized desi gn and is the largest model, with an interior diameter of about 23 feet. Because Entoliter is no longe r in business, IP personnel have taken over the task of repairs

and maintenance.

### Site Visit & PM Testing at In terna tio nal Paper

In general, the scrubber is an upright cylinder divided into top and bottom sections. Flue gas

from the boiler en ters th e lower section an angle, estab lish i ng a circular flow pattern. It then enters a section of turning vane s that direct the gas closer to the center of the scrubber. Associated with the turning vane section are spray nozzles and a pool of water, which generate a

m i st that is carried along with the flue gas.

From inside the turning vanes the flue gas/m i st passes through a hole in a horizontal divider into the upper section of the scrubber. In the upper ha lf the spinning stream of flue gas and m i st expands and slows. Most of the m i st drops out of the flue gas, taking m o st of the sulfur dioxide and particulate m a tter w ith it. The cleaned flue gas exits from the top of the scrubber. Liquid water and sludge is rem oved from the wet scrubber at the bottom

.

Maintenance on the wet scrubber consists prim arily of adding caustic to the water as needed to

m a intain the desired pH, and replacing turn ing vanes and nozzles when they wear out.

IP personnel said the scrubber ha s a design value for L/G of a bout 5 gallons of water per 1000 saturated cubic feet of flue ga s. The water pH, and the am ount of water added to the pool under the turning vanes (known as the “lower flow”) an d to the turning vane spray nozzles them selves (known as the “upper flow”), are controlled to optim ize scrubber efficien cy. Historically, upper

and lower flows have been m a intained around 1580 and 170 gallons per m i nute, and the pH around 5.1. IP personnel said that a few weeks ago they tried to m a ke the upper and lower water flows closer to equal, thinking that this m i ght enhance scrubber efficiency . Based on the results of the particulate em ission testi ng over the last few days, however , they have decided to go back

to som e thing closer to the histo r ic al f l ow setting s

.

After the briefing on the wet scrubber, Mr. W itkowski provided the following summary for the

tota l par ticu l ate em ission s testing to

- d ate (8 p a rticulate em ission tes t runs ):

Test Date TDF (TPH) PM Em issions (lb/MMBtu)

0.11 1 1 / 9 1

. 0

0.096 Avg = 0.10

0.096 1 1 / 1 0 0

. 5

0.095 Avg = 0.096

0.105

0.105 1 1 / 1 3 0

. 2 5

0.070 Avg = 0.093

The em issions lis ted abo v e are no t n ecessarily th e fi nal

, offi ci al result s, b u t they a r e more accurate th an the prev io us, “prelim i nary” results and thus sh ould be clo s e to what becom e the

of

f i cial resu lts. The perm it lim it is 0.1 0 lb/MMBtu

.

As can be seen from the 11/13 data, em issions we re higher than the prelim inary data (without probe wash results) had originally indicated. Probe wash results fr om 11/13 were higher than the other two days for unknown reasons. There was also no obvious explanation why one of the test

Testing on 11/14/06 Page 2 of 3

### Site Visit & PM Testing at In terna tio nal Paper

runs on 11/13 was so m u ch different than the ot her two, or w hy the test results from the three days were so sim ilar even though the TDF feed rate was signifi cantly different on each day. It can be speculated that variation in the quality of the bark fuel ha d an im pact on the test results.

Mr. W itkowski said that, in light of these upda ted results, the need for further testing is question a ble. He noted that corpo r ate officials fro m IP were reviewing the results, and that we were waiting for their comm ents before a final decision would be m a de about the next steps.

After a lengthy wait, Mr. W itkowski announced that the TDF trial burn was officially cancelled,

and no further em ission testing, or burning of TDF, would occur. He provided us with a written press release that provided furthe r details about IP ’s decision, whic h I have included with this trip repor t.

This site visit concluded with a brief, casua l m eeting where all of the governm e nt observers present (th e NY State observer was n o t there beca use stack sampling had not occurred that day) provided IP representatives with a short, verbal summary of their observations and comm ents about the trial burn. Generally, everyone t hought the trial burn em ission testing was well

m a naged, that IP had provided test infor m ation to the observers in a tim ely m a nner, and that IP

had m a de the correct decisi on in stopping the trial.

dm



### Testing on 11/14/06 Page 3 of 3

### Internation a l Paper, Ticonderoga N.Y.

TDF Trial Burn – November 2006

Photographs Page 1 of 2 Prob e and Filter/Im p i n g e r Box in Sam p lin g Po sition o n Power Bo iler Stack

. Ph ot o g ra p h by D a vi d Ma n n i n g ( 1 1/ 1 3

/ 0 6)

Ano t h e r View o f Prob e an d Filter/I m p i n g e r b o x on th e Power Bo iler Stack

Ph ot o g ra p h by D a vi d Ma n n i n g ( 1 1/ 1 3

/ 0 6)

### Internation a l Paper, Ticonderoga N.Y.

TDF Trial Burn – November 2006

Photographs Page 2 of 2 Sam p l i ng Pum p s a n d Ot her C ont rol s i n Act i on Ph ot o g ra p h by D a vi d Ma n n i n g ( 1 1/ 1 3

/ 0 6)

Preliminary Recove ry of Parti c ulate Sam p le

Ph ot o g ra p h by D a vi d Ma n n i n g ( 1 1/ 1 3

/ 0 6)

## Appendix II

Summary of Meteorological Analysis & Air Quality Modeling

Associated with IPC Test Bu rn of Tire-Derived Fuel

Paul Wishinski & Dan Riley

VT DEC: Air Pollution Control Division November 28, 2006The following discussion summari zes the pro c ess by which ground-level air quality moni toring locations were identified for use during a projected test burn of tirederived fuel at the Inter national Pa per Compa n y plant in Ticonderoga , New York. The

test burn w a s announced in 2003 and the V e rmont Air Pollution C ontrol Division determined that is would establish some temporary monitoring locations across the state

border in Ve rmont in ord e r to try to identify (if po ssible) the impact of e m ission cha nges associat ed with the test burn. In or der to assess the effect of burning T D F at the plant, it
was felt tha t a period of baseline monitoring prior to the test burn period would be

desirable. Monitors used for air quality sampling (both pre-test and during the test) were to be placed in locations which had the most likelihood of se eing a plume from the p l ant boiler stack impact at ground level.

The first step in identifying monit o ring locations involve d looking at historica l meteorology from the area. Based on this h i st orical data, we ran a n u merical impact

assessment model calle d CALPUFF (a puff disp ersion model) to simulate the potential impact area s from emissions comin g from t he I P C main boiler sta ck. A test mode ling year of 2000 was used for this det ailed examination. Year 2000 meteorology was not

deemed to be significan t ly different than the l ong-term climat ological met eorology for the area. In addition to p e rforming a detailed year-long model analysis, field visit s to
locations alo ng the eastern shore of Lake Champlain across from the International Paper Compan y plant in New York were carried out o n several days in the fall of 2003.

Running CALPUFF for the entire year 2000 using a detailed (2.0 kilometer gridded wind fields) set of meteorology and kno w ing the characteristics and details of the locations pr edicted to show potentially highest impacts gained through our field visits,

two location s at about 4.5 to 5 kilometers from t he IPC boiler stack were identified. It wa s determined that these t w o sites we re acceptab le for pla c in g the sampling equipment needed and would give the best chance at getting transpor t from the I P C stack to the

monitor locations durin g a short time period test burn. Both these locations were in



### Shoreham , Verm ont.

Page 2 of 17Page 3 of 17Photograp hs sho w i ng the IPC plant and associated plume taken during Fall 200 3
field surve y

.

Page 4 of 17Additional photographs sho w i ng t he IPC plant and associated plume taken during

Fall 2003 fi eld surve y

.

Page 5 of 17Ortho-photograph show in g the IPC plant, southern Lake Champlain, and surrounding areas to the east (mostl y in Vermont) of the plant’s location at Ticonderoga, New Yor k

.

Page 6 of 17Detail from a land surve y map sho w i n g the IPC plant, southern Lake Champlain, and surrounding areas to the east (mostl y in Vermont) of the plant’s location at Ticonderoga, New Yor k . The IPC plant site is under the RED hexag on. The t w o air quality sam pling sites i dentified using CALPUFF modeling and site visits are

show n as BLUE triangl es.

Page 7 of 17Photograp hs sho w i ng the locations chosen for the tw o ambient air quality monitoring locations to be used for preliminary base ca se monitoring and for sampling during an y p o tential tire-derived fuel burn.

Page 8 of 17Page 9 of 17Pattern of annual average impacts predicted from a generic constant tes t emission rate from the IPC boiler stack modeled using the CALPUFF dispersion

model for a one y ear ti me period. Tw o lobes of higher p o tential impact in Vermont are indicated, one to the north-northeast of the IPC pl ant and one to the southw est of th e IPC plant. The spe cific locati ons selected for ambient monitoring based on this pattern w e re de termined from considerations related to th e availability of po w e r, a ccess, and security of expensive monitoring equipment that

had to be placed in t he field an d operated for long ti me periods (the monit o rs placed ac tuall y ended up b e ing operated for more than 3 y ears).

Page 10 of 1 7Another de piction of the pattern of annual average 1-hour impacts predicted from a generic constant test emission rate from the IPC boiler stack modeled usi ng the
CALPUFF dispersion model for a one y ear time perio d. Both c hosen mon i tor locations are indicated as having the potential for abo ut the sam e level of a nnual average impact (y ellow pattern j ust touchi ng these l ocations) a nd that im pact being at about the highest impact level expected for an annual average for an y location in Vermont, e xcept for a few locatio ns on higher terrain to the southeast
and further a w ay from the plant w h i ch coul d have slig htl y higher impact levels.

Page 11 of 1 7This depiction sho w s t he pattern of the number of 24-hour impacts above a cutpoint level (0.20 ug/m3) predicted from a generic constant test emission rate from the IPC boiler stack modeled using the CALPUFF d i spersion model for a one

y ear time p e riod. Both chosen monitor locations are indicated as having the potential for about the same number of 24-hour impacts higher than 0.20 ug/m3 (pink pattern just touching these locations). This indicates approximatel y 14 d a y s during 2002 w hen the 24-Hr impa ct w o u l d ha ve been higher than the cutoff chosen. It appears from the pattern that possibl y a cou ple other locations on higher ground to the southeast and further aw ay might have had as man y or a few

more such da y s

.

Page 12 of 1 7Another de piction show in g the pa ttern of the number of 24-hour impacts above a cutpoint level (0.20 ug/m3) predicted from a generic constant test emission rate from the IPC boiler stack modeled using the CALPUFF d i spersion model for a one

y ear time p e riod.

Page 13 of 1 7Another de piction show in g the pa ttern of the number of 3-hour impacts above a cutpoint level (10.0 ug/m3) predicted from a generic constant test emission rate from the IPC boiler stack modeled using the CALPUFF d i spersion model for a one

y ear time p e riod. The location on higher terrain to the southeast of the IPC Pla n t in Vermont State might be expected to have the most potential for these relativel y short-term higher impacts.

Page 14 of 1 7Another de piction show in g the pattern of th e number of 1-hour i m pacts above a cutpoint level (100.0 ug/m3) predicted from a generic co nstant test emission rate
from the IPC boiler sta ck modeled using the CALPUFF dispersion model for a one

y ear time p e riod. These high very short term impacts are predicted to occur onl y in the high terrain to the w est of t he IPC Pl ant in Ne w York State.

Page 15 of 1 7This depiction sho w s the pattern of the highest 24-hour impacts predicted from a generic constant test emission rate of about 7.9 lbs/hour (1 gr/se c ) from the IPC

boiler stac k modeled using the CALPUFF dispersion model for a one y ear time period. The predicted maximums in Vermont (0.50 –> 0.75 ug/m3) are in the pink

zones sho w i n g predominantl y to the northeast and southeast of the IPC Pl ant. Both sampl ing locations chosen are at the e dge of one of those pi nk zones. NOTE
that this emission rate is only for referenc e and DOES NOT REPRESENT ANY
ACTUAL POTENTIAL EMISSION SPECIFIC TO THE IPC PLANT.

Page 16 of 1 7This depiction show s the pattern of the hig hest 1-hour impacts predicted fro m a generic constant test emission rate of about 7.9 lbs/hour (1 gr/se c ) from the IPC

boiler stac k modeled using the CALPUFF dispersion model for a one y ear time period. Th e predicted maximum s in Vermont (4 –> 6 ug/m3) are in the blue and

y e llow zon es sho w i ng to the sout heast of th e IPC Plant. Neither sa mpling loca tion
chosen is w i th in one of those zo nes, but fo r a short-term test period the location of the maximum 1-Hr potential impact point during a one y ear period is not

necessaril y the criterio n that best locates sampling equipment for detection of the

test emissi ons. NOTE that this e m ission rate is only fo r reference and DOES NOT

REPR ESE N T ANY A C T UAL P O TE NTIAL E M I SSION SPE CIFIC TO T H E IPC PL ANT.

Page 17 of 1 7

# Appendix III

Summary Analysis of Transport Wind Fields

Period from November 5 to November 14, 2006

IPC Test Burn of Tire-Derived-Fuel

VT DEC: Air Pollution Control Division

Paul Wishinski & Dan Riley November 28, 2006PRELI M INARY MODEL I NG RESUL T S for the TEST PERI OD (November 5, 2006 to November 14, 2006):

On the follo wing pages are shown a set of daily maps of the area within about 10

kilometers of the IPC Plant which depict the average daily modeled impact fr om a generic test emission rat e of 10 lb s/h our from the IPC boiler stack. T here are two maps
associat ed with each day in this 10 day period. For each day, the first map depicts the predominant wind directions seen f r om the modeled wind fields durin g that 24 hour period. The second ma p for each d a y depicts t he location of highest a v erage imp a cts from the IPC stack gen eric emissio n of 10 lb s/h our, which, if winds hav e been relatively persistent fo r the day shows up as t he location of a plume of impact.emanating from the plant. If win d s are less persistent in one directio n, the patter n of impact can be seen to be more dispersed arou nd the plant, rather than in only one narrow direction.

CALPUFF was run wit h the constant generic emission rate for the IPC boiler

stack and u s ed 3-dimensional win d fields developed from National Weather Servic e meteorological models that had been in itialized with the most recent a c tual

measureme n ts for the 24 hour time period of the day. T he wind fields used to drive
CALPUFF were therefore only available for a given date at about 7 a m of the following day. Each day these NWS Met fields were used to ge nerate localized detaile d 3-
dimensional wind fields over the s m a ll domai n included on the map s shown. The CALMET meteorological model was use d in conju n ction with detailed t e rrain representation to alter t he initializat i on data obt ained for th e upper air from the NWS

modeled fields while sur f ace measurements at the northern ambient air quality sampling

location were also incor porated. Th ese results are prelimin ary for this initial report

, and may be adjusted as more careful examination of the mod e led output is performed and quality assurance of the input mete orological fields is done. As soon as any validated

actual test e m ission dat a is availabl e additional modeling will be done to more accurately represent impacts.

NOTE: The i m

pacts depicted are not actual im pacts but only relative spatial patterns based on a GENERIC 10 lb s/hour CONSTANT HOURLY EMISSION RATE.

Page 2 of 22The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 3 of 22

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 4 of 22The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 5 of 22

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 6 of 22The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 7 of 22

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 8 of 22The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 9 of 22

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 10 of 2 2The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 11 of 2 2

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 12 of 2 2The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 13 of 2 2

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 14 of 2 2The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 15 of 2 2

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 16 of 2 2The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 17 of 2 2

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 18 of 2 2The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 19 of 2 2

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 20 of 2 2The red arrow is a subje c tive representation of t he plume centerline for t he time period
identified ba sed upon th e output of t he plume dispersion model.

Page 21 of 2 2

### GREEN = Generic Impact of > 1 Unit

ORANGE = Generic Impact of > 4 Units

RED = Generic Impact of > 6 Units

BLUE = Generic Impact of > 12 Units

Page 22 of 2 2