Date: November 14, 2006, 12:26 AM

To: "Barbara Ernst" <bernst@gmavt.net> From: Neil Carman <neil_carman@greenbuilder.com> Subject: Re: Fw: IP Tire Test Burn Violation: Immediate Halt to IP Tire Test Burn for Violating Test Protocol & Failing to Protect Public Safety: Cc: "B J Ernst" <thebarbs@gmavt.net>, "Richard Carpenter" <Richcarpenter212@cs.com>, "Tom Vanacore" <stones32 @sover.net> Bcc: Dear BJ, You need to investigate several areas to substantiate the concerns that you are raising over IP TDF Test Burn. 1. Do you have any written medical confirmation of air pollution

- induced illnesses by Vermont physicians since IP s tarted the TDF Test Burn? People who are becoming ill from the air pollution need to have written confirmation from a medical doctor as a result of a visit to their doctor or respiratory

- lung specialist or emergency room, and maybe one or more physicians would indicate that their illness is air pollution related. Without written confirmation by a physician, the reports of air pollution

- induced illnesses are purely anecdotal and will not carry very much weight with elected officials, government regulatory a gencies or the media. It's critical to have a physician confirm the illness and if possible, give a written opinion that it's due to "air pollution." In Texas, a letter from a physician that a person's illness is due to industrial air pollution can trigge r violations against the suspected industrial plant especially if they had reported upset emissions. The letter from a physician is taking seriously. Or if sick people have had to go to an emergency room for help breathing, once again these reports are ta ken more seriously.
2. Have you collected written letters from any of the specific persons who have become ill allegedly in association with the particulate emissions and gases due to the IP TDF Test Burn? Even though these letters are purely anecdotal, it would still be useful todocument their illnesses.

3. Have any of the specific persons who have become ill due to the IP TDF Test Burn filed written or oral complaints with the state of Vermont? I strongly encourage you to get every one of these ill person to write a short letter and file complaints with the state of Vermont.
4. Have you shared any of this information of air pollution

- induced illness due to IP's TDF Test Burn with IP officials and NYSDEC officials?
5. Have you shared any of this information of air pollution

- induced illness due to IP's TDF Test Burn with New York and Vermont elected or regulatory officials?
6. Meteorological conditions need to be confirmed showing that the winds have been blowing fr om IP into Vermont. You can usually obtain weather data from the National Weather Service or local tv stations. But I think for sure you need weather data showing the wind conditions from like 160

- 190 degrees SE

- South from IP or whatever the wind directio n has been during the days of the TDF testing. I am sure it's common to have southerly winds but in the winter time, fronts often blow the winds from the northerly direction. I have not checked the local weather conditions for southern Vermont over the las t week. You need certified A) Hourly Average Wind Speed and B) Hourly Wind Direction data from a calibrated meteorological station and your local NWS or weather tv person can tell you how to find it. Some states have met data online related to the ambient air monitoring networks they operate.
7. Smell of burning tires? Have any of the people reporting illnesses during this period also confirmed smell of burning rubber particularly with the winds blowing from thesoutherly direction from IP into Vermont ? I know residents who have

complained of burning rubber one mile downwind of a cement kiln burning whole tires.
8. Ambient air monitoring? Are there any ambient air monitoring stations located between IP and Vermont that are operated by the state of Ve rmont or in the state of New York by the NYSDEC? Ambient air monitoring data might be helpful to confirm if the PM10 levels have increased during the TDF testing.
9. What TDF Stack Test Data do you have from IP's TDF Test Burn? I n eed to review a written report from the IP TDF Test burn but normally reports are not available until long after the testing is over! What is your source of information about high PM10 levels at IP during the TDF Test Burn?
Thanks, Neil

*************** **************************************************************** NEIL J. CARMAN, PH.D. Clean Air Program director Lone Star Chapter of Sierra Club http://www.texas.sierraclub.org, 1202 San Antonio street Austin, Texas 78701 512

- 472

- 1767 Phone 512

- 477

- 8526 Fax Email: Neil_Carman@greenbuilder.com Sustainable Sources for the Planet: http://www.greenbuilder.com Volunteer scientist on Sierra Club's Genetic Engineering Committee: http://www.sierraclub.org/biotech
************************************************* ****************************** At 12:35 AM

- 0500 11/14/06, Barbara Ernst wrote:Monday, 11/13/2006, 11:50PM EST

Fw : IP Tire Test Burn Violation: Immediate Halt to IP Tire Test Burn for Violating Test Protocol & Failing to Protect Public Safet y:
Neil, IP has completely violated even it's own flimsy test protocol. See specific notes below from last Thrusday. In addition to these they exceeded the Particulate Federal Limit last Thursday a 1 ton per hour tdf and had been running since Tuesday, 11/ 7 at 1 ton tdf but refused to do any PM measurements (PM 10 and greater only no PM 2.5 at all because of the alleged moisture in the stack..) They ran nonstop for 40 hours over 3 days 11/7

- 11/9 without any PM measurements until Thursday afternoon 11/9 wh ere the test showed they passed .10 fed limit on PM at .109. Their baseline PM was .05 with the oil and wood mix. They are also only supposed to test during daylight hours and with obervers and they ran through the night 11/7 and 11/8 and took TDF out of mix on Thrusday evening when their tests showed they passed the federal PM limit. The VT DEC has failed in enforcing IP's own test protocol, see below, and allowed 40 hours of double baseline and over federal pllution limits of .100 at .109 causing severe adverse health effects. People are getting incredibly ill from the Tire Burn w/out ESP Pollution Controls. People who have never had any respiratory illness whatsoever have developed severe respiratory airway disease since the IP Tire Burn started on Tu esday 11/7 and has sent many folks to the ER unable to breath. See following email on health (see end of email for update email that went out yesterday) Please check out the link to the state's website for recent daily observes. And they put and IP PR S pin statement in the VT DEC's Website on observations. They seem to be very IP favorable as they have failed to ensure that IP adheres to their own protocol We have asked the Gov and the DPH Commissioner to step in and useexecutive power to stop the ti re burn immedately as people in VT are

getting very sick and we hope to engage them to do so. In that regard, could you look at this data and the website link below for VT DEC IP Tire Burn Site and People for Less Pollution site with the up to minute updat es on burn and write a professional oppinion of the outragous test violations and that the test should be stopped immediately to protect public health as all TDF operations have either ESP and/or BagHouse filter systems as standard equipment and to run a t est without either of those is a real endangerment to public health. Obviously mentioning that you are an expert on Tire Incineration Stack Testing, and your Background, etc to establish your true position to make these observations. We can then present t his to our Gov and DEC and DPH and give them a basis to shut down this dangerous IP Tire Burn Test Immediately. Please help us. We are all getting very ill and IP doesn't care and the NY & VT DEC doesn't care either. They are trying to deny their have be en any mistakes or endangerment to public health. We need some solid ammunition here. Also, would you be available to be hired by either us or our state to observe and oversee the IP Testing as a true independent expert. IP paid for the current testers and VT isn't doing their job. Please let us know on that as well. We made a request that the ambient air quality testing beiing done in VT be analyzed immediately for data on what we've been exposed to but our DEC Commissioner said they are running testin g for 6 weeks and then will send all samples out then and the data will take another 4

- 6 weeks analysis. Is there any reason the VT DEC can't get an expedient analysis ( see letter to Jeff Wennberg, VT DEC below) in a shorter time to help address the se vere health affects from the tire burn. Your thoughts?? We are presenting to the governor tomorrow morning, and also the lieutenant governor. Is it possible you could put something together we could present to them to get them to invoke their executive p ow er to protect Vermonters from this eminent health threat?? If we don't stop them tomorrow the Gov will probably take no action so we're trying to give him the best case possible. Thanks so much! Please get back at your earliest convenience tomorrow ear ly hopefully. See previous emails for reference if necesssary. The People for Less Pollution Website and the VT DEC IP Tire Burn Website has everything in one place for ease of review.Thank you so much. We really really need your help now to protect our

health from this crazy IP unconscionable polluter. Many Many Thanks! BJ Ernst, Executive Director Northeast Clean Air Coalition (NECAC) PO Box Vergennes, VT 05491 802

- 759

- 2259 Phone/Fax email: <mailto:bernst@gmavt.net> bernst@gmavt.net PS. We got a return call from Jane xxx director of Sierra Club's National Air Toxics Program. Too late to call her back tonight? Any idea if she can help us? How so?? <http://www.anr.state.vt.us/air/htm/iptireburn.htm> http://www.anr.state.vt.us /air/htm/ iptireburn.htm <http://www.lesspollution.org> www.lesspollution.org for all updates and stats as well.
***************************** Monday, 11/13/06 8:39AM EST Jeff Wennberg, Commissioner VT Dept. of Env. Conservation Waterbury, VT Re: IMPORTANT: Tec hnical Questions Re IP Tire Burn, Please get back ASAP today: Jeff, Can VT DEC send the first week's testing out immediately for analysis vs. waiting for the entire 6 week period of data collection and then several additional weeks period for analysis a s is the previously communicated plan for testing?? It is important that we have some ambient air quality data as soon as possible (especially PM 2.5 & PM 10 and Zinc & Mercury testing) to know what the results are from this last week of IP Tire Burnwith out Industry Standard Pollution Controls. Data 8

- 10 weeks from now

will not be helpful in the state's case to stop IP from proceeding for a permanent application to burn 72/tons of tires daily w/out Industry Standard ESP 95% Particulate Removal Pollution Controls and IP has stated that it intends to do so as soon as possible. The state of Vermont needs every advantage to be able to stop a permanent application to burn tires w/out Ind. Std. Pollution Controls to allow it to prevail in this matter. Please get back as soon as possible today on this. BJ Ernst, Executive Director Northeast Clean Air Coalition PO Box 95 Vergennes, VT 05491 802

- 759

- 2259 Phone/Fax <> bernst@gamavt.net , <> necac1@yahoo.com

----- Original Message

----- From: <>W ennberg, Jeff To: <>Barbara Ernst Sent: Tuesday, November 07, 2006 10:35 AM Subject: RE: IMPORTANT: Technical Questions Re IP Tire Burn, Please get back ASAP today: Barbara, Here is some additional information:
November 2, 2006

Air Pollution Ambient Monitoring Network Shoreham, VermontAmbient monitoring began at South Shoreham site 11/29/2003.

Ambient monitoring began at North Shoreham site 01/01/2004.

PM10 every 6

- days (filters may subsequently be analyzed for individual metal constituents) PM2.5 every 3 days Meteorological (wind speed, wind direction, temperature) at North site only

Enhanced/increased monitoring for the trial burn period:

? PM10 and PM2.5

- now every day at both sites (select samples to be analyzed for individual constituents at a later date based on review of all other data). ?Meteorological now at both sites as of 10/31/2006. ?Particulate „DRUM‰ samplers operating at both sites starting simultaneously at 9:00 AM, 11/1/2006 (Dr. Tom Cahill, affiliated with University of California Davis). These will run for six weeks, collecting particulates into separate size fractions that can be individually a nalyzed for separate metal constituents. ?Mercury monitoring at the northern Shoreham site starting 10/18/2006 (contract with Dr. Eric Miller, of Ecosystems Research Group, LTD). Tekran unit that measures 1) elemental gaseous mercury 2) reactive gaseous mercury 3) particle phase mercury. Yields a 2 hour average every 3 hours. Collects sample for 2 hours then analyzes the sample during the 3rd hour. ?Polycyclic Aromatic Hydrocarbons (PAH), TEOM (continuous PM2.5), RAAS sampler (PM2.5 mass, elemental par ticulate matter speciation withXRF, sulfates, nitrates, carbon, and fine particle nitrate), OCEC analyzer

(organic carbon and elemental carbon), aethalometer (organic carbon and black carbon), trace sulfur dioxide and particle size distribution monitoring by spectrometer (contract with Dr. Hopke, affiliated with Clarkson University). PAH, TEOM and RAAS equipment at both sites will begin operation on 11/04/2006. All others are North site only and began operation 10/27/2006, except the particle distributio n monitor, which is installed but not yet operational.

Jeff

****************************

----- Original Message

----- From: <mailto:bernst@gmavt.net>Barbara Ernst To: <mailto:Jeff.Wennberg@state.vt.us>Wennberg, Jeff Cc: <mailto:rlarose@vdh.state. vt.us>rlarose@vdh.state.vt.us ; <mailto:lcrist@vdh.state.vt.us>lcrist@vdh.state.vt.us ; <mailto:doug.elliott@state.vt.us>doug.elliott@state.vt.us ; <mailto:Dick.Valentinetti@state.vt.us>Dick.Valentinetti@state.vt.us ; <mailto:Canute.Dalmasse@state.vt.us>Da lmasse, Canute ; <mailto:smoffat@vdh.state.us>smoffat@vdh.state.us ; <mailto:bbress@state.vt.us>bbress@state.vt.us ; <mailto:thebarbs@gmavt.net>B J Ernst Sent: Friday, November 10, 2006 11:18 AM Subject: Fw: IP Tire Test Burn Violation: Immediate Halt to I P Tire Test Burn for Violating Test Protocol & Failing to Protect Public Safety: Thursday, November 9, 2006 8:00pm EST Jeffrey Wennberg, Commissioner Canute Dalmasse, Acting. Scty. ANR Dick Valentinetti

- Air Quality Program Director Doug Elliot

- Air Quality Program VT Department of Environmental Conservation103 South Main St.

One South Building Waterbury, VT 05671

- 0401 802

- 241

- 3808/802

- 244

- 5141

- Fax email: <mailto:jeff.wennberg@state.vt.us> jeff.wennberg@state.vt.us, <mailto:canute.dalm asse@state.vt.us> canute.dalmasse@state.vt.us, <mailto:dick.valentinetti@state.vt.us> dick.valentinetti@state.vt.us, <mailto:doug.elliott@state.vt.us> doug.elliott@state.vt.us VT Dept of Public Health Sharon Moffatt, Commission Larry Crist, Director Public Health Protection Brett Larose, Public Health Protection VT Governor Jim Douglas

IP Tire Test Burn Violation: Immediate Halt to IP Tire Test Burn for Violating Test Protocol & Failing to Protect Public Safet y:

Follow

- up on IP Ticonderoga, NY Tire Burn Test Protocol Violation for PM Stack Measurement and TDF Burn Time Duration: Jeff, Canute, Dick & Doug, Health Commissioner Moffat, Dept Health & Governor Douglas, Upon further investigation of the IP Testing Protocol t here are specific violations occurring with IP's Tire Test Burn as follows: According to Section 2

- 6 Power Boiler: page 5 of the IP Tire Burn Test protocol the text reads as follows:

"Particulate emissions from the boiler are controlled with multi

- clones and an Entoleter wet

- alkaline scrubber. The scrubber removes approximately 76% of the particulate and emits approximately 0.06 lbs/MMBTU particulate, with a NYSDEC permit limit of 0.1 0lbs/MMBTU. IP will conduct a two

- week TDF trial program. During the first week IP will ramp the TDF feed up from 0 tons per hour to 3.0 tons per hour in 1/2 tonincrements to ensure stable boiler operations. During the one

- week ramp

up and shake down p eriod, testing will be performed to determine emissions of PM at 1tph TDF, 2 tph TDF and 3 tph TDF. Testing will be performed to ensure that the current permitted PM emission rate is not exceeded. It is anticipated that triplicate 60

- minute tests will be performed at each firing rate over a three

- day period. Analyses will be performed on

site for a timely quantification of test results (same day preliminary, next day final results). The actual TDF emissions testing will be conducted during the second w eek of feeding TDF to the boiler. During this second week, emission measurements will be performed with the Power Boiler firing bark/wood and fuel oil with up to 3 tons per hour TDF. The boiler will be operated close to its normal maximum neat input rate of 748 MMBtu/hr which produces 550,000 lb/hr of steam. As per request by US EPA, test days will be limited to 12 hours in duration. After the TDF trial is completed, additional testing will be devoted to measuring emission under baseline/normal condit ions (i.e.. bark/wood and fuel) without TDF. Boiler parameters to be continuously monitored and continuously recorded (1

- minute averages) by the facility during the emissions test are present in Table 2

- 1: " 1. According to the IP test protocol sited above, IP should have been doing PM testing every day since beginning the test on Monday 11/6/2006 preliminary, 11/7 & 11/8 full testing at 1 tph TDF "to ensure that the current permitted PM emission rate is not exceeded." but failed to do so. Therefore th e PM generated for 11/6, 11/7 & 11/8 is unknown and fails to meet IP's own test protocol criteria. This is an endangerment to public health to have no date for 2

- 3 days while TDF burning was occurring. 2. Also, in the next paragraph above it state th at "the boiler will be operated close to its normal maximum heat input rate of 748 MMBtu/hr..." It should be noted that the maximum boiler rate at 100% full permit capacity is 855 MMBtu/hr. (see note from Tire Incineration National Expert, Dr. Neil Carm an, Sierra Club, Clean Air Director below, that regulatory stack tests are required to be performed at 100% boiler capacity as allowed in the permit and IP has refused to run at 100% as they know their 1970 oldinefficient boiler will generate over regulat ion limits of PM 2.5+ at the 100%

full boiler capacity. However post test they are allowed to burn at this higher rate and way exceed all pollution limits. This fact alone makes the entire test completely invalid and the data non

- credible. 3. According to the second paragraph above from the IP Test Burn Protocol the following is outlined, "As per request by US EPA, test days will be limited to 12 hours in duration." Therefore it is a violation of the test protocol for IP to attempt to burn TDF all night as they proposed to do on Wednesday, 11/8/06 and possibly other days as well. 4. Note that IP plans on burning the higher

- grade tire

- derived fuel during the test burn and a lower

- grade more metal containing TDF on a regular basis. No chemical composit ion data given on Tire chips

"Dr. Neil Carman PhD, Tire Incineration National Expert, Sierra Club Clean Air Director, TX Comment on Paragraph 7. The higher
- grade tire
- derived fuel burned during the test burn will not have the same composition as the lower
- grade TDF which will be burned if the plant is granted permission to burn TDF on a regular basis.
According to standard regulatory requirements for stack performance test protocols to measure the emissions on combustion unit s, IP needs to conduct a TDF test burn that is representative of the normal operating conditions of the boiler at the maximum boiler fuel feed rate of 855 MMBtu/hr since that is the rate authorized in the NYSDEC air permit applicable to boiler and the rate applicable to the maximum allowable emission rate limitations (pounds per hour and tons per year) for the criteria pollutants listed in the air permit. IP needs to conduct the stack test at the maximum operating rate it intends to run the boiler at, or am end its boiler permit. But instead IP proposes to conduct a non

- representative TDF test burn firing the boiler at an artificially reduced rate of 748 MMBtu/hr (12.5% lower than maximum permitted boiler feed rate) due to concerns over exceeding the boiler's maximum allowable permitted emissions rate for particulate matter of 0.10 pounds/MMBtu in the current Title V permit, andyet IP does not propose to revise its boiler maximum fuel rate of 855

MMBtu/hr to 748 MMBtu/hr. IP has failed to provide representat ions on the mercury concentrations of the TDF material they propose to burn in the boiler based on their own metal analysis of the TDF chemical composition and they have not cited representative mercury concentrations from the supplier of the TDF chips." IP should be following their own test protocol and if they fail to do so they should stop the test until they comply with their own test protocol. VT DEC cannot allow IP to fail to comply with the testing protocol and must insist the IP follow their test protocol to the last detail as that is what has been approved, nothing else.
See VT DEC Website on Daily IP Tire Burn Updates, Permits, Test Protocols, etc. <http://www.anr.state.vt.us/air/htm/iptireburn.htm> http://www.anr.state.vt.us /air/htm/iptir eburn.htm
Contact Info for Dr. Neil Carman PhD. Tire Incineration Expert NEIL J. CARMAN, PH.d. Clean Air Program director Lone Star Chapter of Sierra Club <>http://www.texas.sierraclub.org, 1202 San Antonio street Austin, Texas 78701 512

- 472

- 1767 Pho ne 512

- 477

- 8526 Fax Email: <>Neil_Carman@greenbuilder.com Sustainable Sources for the Planet: <>http://www.greenbuilder.com Volunteer scientist on Sierra Club's Genetic Engineering Committee: <http://www.sierraclub.org/biotech>http://www.sierraclub.org/biotech
Because of IP's failure to follow their own test protocol and endangering public safety as detailed above, we are calling for the VT State Health Dept, VT Governor and VT DEC to call a n immediate halt to this public health endangering test. Please respond as soon as possible in theinterest of protecting Vermont's children, citizens, farms and environment.

Best, BJ Ernst, RN, CCRN, BS, BSN, MRE, Executive Director Northeast Clean Air Coalition (NECAC) PO Box 95 Vergennes, VT 05491 802

- 759

- 2259 Phone/Fax email: <mailto:bernst@gmavt.net> bernst@gmavt.net

----- Original Message

----- From: <mailto:bernst@gmavt.net>Barbara Ernst To: <mailto:Jeff.Wennberg@state.vt.us> Wennberg, Jeff Cc: <mailto:Canute.Dalmasse@state.vt.us>Dalmasse, Canute ; <mailto:dick.valentinetti@state.vt.us>dick.valentinetti@state.vt.us ; <mailto:doug.elliott@state.vt.us>doug.elliott@state.vt.us Sent: Thursday, November 09, 2006 10:40 AM Subject: IP Tire Test Burn Violation: Immediate Halt to IP Tire Test Burn for Violating Test Protocol & Failing to Protect Public Safety: Thursday, 11/9/2006 9:00AM
Jeffrey Wennberg, Commissioner Canute Dalmasse, Acting. Scty. ANR Dick Valentinetti

- Air Quality Program Director Doug Elliot

- Air Quality Program VT Department of Environmental Conservation 103 South Main St. One South Building Waterbury, VT 05671

- 0401 802

- 241

- 3808/802

- 244

- 5141

- Fax email: <mailto:jeff.wennberg@state.vt.us > jeff.wennberg@state.vt.us, <mailto:canute.dalmasse@state.vt.us> canute.dalmasse@state.vt.us, <mailto:dick.valentinetti@state.vt.us> dick.valentinetti@state.vt.us, <mailto:doug.elliott@state.vt.us> doug.elliott@state.vt.usRe: International Paper Ticonde roga Tire Burn Test: No Particulate

Testing after 2 Days of Burning Tires +: Immediate Halt of IP Tire Test Burn for Violation of Test Protocol:
Jeff, Canute, Dick, Doug, We are very concerned that according to the updates from VT DEC staff that the re has been NO Particulate Testing done since Tires have been introduced into the fuel mix at 8:30am on Tuesday 11/7/06. This is not compliant with their own testing protocol. We see no indication that any other testing is being conducted either including CO, CO2, SO2, NOx, Dioxin, PAH,Mercury, Metals, etc. It was our understanding that IP would be adhering to their own testing protocol which it is clear they are not and that if any limits for any of these and other criteria were surpassed at any point t hat the test would be immediately halted. How can that be determined if there is not testing being performed with the tires in the fuel mix. Vermont should call for an immediate halt of this test from proceeding as it is not complying with even it's own te sting protocol. Particulate levels (PM 2.5 +) were measured on Monday for baseline and tires have been burning since Tuesday with no additional testing. This is unacceptable and VT DEC should call for the test to be stopped immediately for failing to com ply with IP's own testing protocol. It is our understanding that is why VT is supposed to be present during all TDF trial periods. Which according to Doug's update note from yesterday IP was allowed to burn TDF throughout the evening with no other observe rs present. That is also unacceptable. TDF should not be burned in the fuel mix unless there are full observers present and if that is only during the day from 8am to 4pm than that is the only time that they should be burning tires in the fuel mix. How can VT observe and/or object to protocol, testing, etc if they are not present. Because of this we are asking VT DEC to call an immediate Halt to the IP Tire Test Burn for violating it's own testing protocol and not testing for particulates and other pollut ants ongoing to ensure that they do not exceed regulatory limits for any of these pollutants whatsoever and endangering the public safety of Vermonters. Please get back to us as soon as possible today.Best,

BJ Ernst, Executive Director Northeast Clean Air Coalition (NECAC) PO Box 95 Vergennes, VT 05491 802

- 759

- 2259 Phone/Fax email: <mailto:bernst@gmavt.net> bernst@gmavt.net

11/9/2006

- International Paper conducted the particulate compliance testing at the one ton per hour rate toda y. The testing consists of three individual measurements, after each measurement, the resulting sample is analyzed. IP has decided to remove tire derived fuel from the fuel mix until these test results are available. We expect IP to have these test results tomorrow.

11/8/2006

- International Paper continued firing TDF at the rate of 1 ton per hour throughout the day today. They did not begin particulate compliance testing at this rate today as we had expected. This was in order to give their boiler operat ors additional experience at this firing level. They are expected to continue at 1 ton per hour through the night tonight, with a short interruption for normal maintenance. Particulate matter testing at the 1 ton per hour rate is expected to begin Thursday morning. Preliminary results may be available later in the day. Provided the results demonstrate compliance with their permit limit, IP is expected to increase the firing rate to 2 tons per hour late tomorrow. Because of the delay with the wood bark feedi ng system no tire derived fuel (tdf) was burned today. We expect that they will begin with a 1/2 ton per hour rate of tdf tomorrow morning.

11/7/2006

- Following completion late yesterday of the baseline particulate test, IP introduced tire derived fuel (tdf) into the solid fuel mix at 8:30 am this morning and the tire chips actually got to the boiler around 9:30 am at the rate of 0.5 ton per hour, throughout the day this was increased to 1 ton per hour and the boiler has now been stabilized at this level . A particulate test will be required to confirm that IP is still within their permit limits beforethe tdf can be increased in the next phase to 2 tons per hour. A meeting

was still going on at 4:30pm to set the schedule for tomorrow when IP will carry ou t the first particulate test with tdf in the fuel mix. In other activities today time was spent ensuring the calibration of the tdf percentage

- to confirm that the tire chips are being fed at the rate described. VT DEC staff report that the calibration we nt well and they are satisfied it is an accurate number.

11/6/2006

- International Paper spent most of today, the first day of the tire burn test, setting things up. Under the permit they are required to carry out a baseline particulate test at the begin ning of the process, but this test was held up for much of the day due to a non

- tire related problem with the wood bark feeding system. (Wood is necessary for the particulate test). Because of the delay with the wood bark feeding system no tire derived fue l (tdf) was burned today. We expect that they will begin with a 1/2 ton per hour rate of tdf tomorrow morning. Wed, 11/8/2006 IP Ticonderoga Tire Burn Test Report: Doug Elliot, VT DEC Air Quality Division: International Paper continued firing TDF at th e rate of 1 ton per hour throughout the day today. They did not begin particulate compliance testing at this rate today as we had expected. This was in order to give their boiler operators additional experience at this firing level. They are expected to continue at 1 ton per hour through the night tonight, with a short interruption for normal maintenance. Particulate matter testing at the 1 ton per hour rate is expected to begin Thursday morning. Preliminary results may be available later in the day. Provided the results demonstrate compliance with their permit limit, IP is expected to increase the firing rate to 2 tons per hour late tomorrow.
Tues, 11/7/2006 IP Ticonderoga Tire Burn Test Report Following completion late yesterday of the basel ine particulate test, IP introduced tire derived fuel (tdf) into solid the fuel mix at 8:30 am this m orning and the tire chips actually got to the boiler around 9:30 am at the rate of 0.5 ton per hour, throughout the day this was increased to 1 ton per ho ur and the boiler has now been stabilized at this level. A particulate test will be required to confirm that IP is still within their permit limits before the tdf can be increased in the next phase to 2tons per hour. A meeting was still going on at 4:30 pm to set the schedule for tom orrow when IP will carry out the first particulate test with tdf in the mix fuel mi x. In other activities today time was spent ensuring the calibration of the tdf percentage

- to confirm that the tire chips are being fed at the rate described. VT DEC staff report that the calibration went well and they are satisfied it is an accurate number. Justin Justin Johnson Communications Coordinator Verm ont Department of Environmental Conservation ph: 802 241 3803 cell: 802 236 4030 em ail: <mailto:justin.johnson@state.vt.us> justin.johnson@state.vt.us Sunday, 11/12/06 9:30PM EST
Re: We Need Your Immediate Help to Halt the IP Ticonderoga, NY Tire Burn w/out ESP Pollution Controls Immediately. Pollution From IP T ire Burn & Plant Causing Severe Adverse Health Affects throughout VT and NY. Please Contact Us Immediately, Northeast Clean Air Coalition (NECAC), BJ Ernst, 802

- 759

- 2259, <> bernst@gmavt..net, <> necac1@yahoo.com :
Dear Green Company Presidents, VPs & Directors, We Need Your Immediate Help to Halt the IP Ticonderoga, NY Tire Burn w/out ESP Pollution Controls Immediately. Pollution From IP Tire Burn & Plant Causing Severe Adverse Health Affects throughout VT and NY . Please Contact Us Immediately: The IP Tire Burn began last Monday 11/6/2006 and has causedwidespread

adverse health affects throughout VT, NY and the region. IP has exceeded all pollution limits for particulates and ran 40 hours at over federal & st ate particulate regulations refusing to measure particulates as required in their test protocol and exposing the public to extremely dangerous toxic substances causing widespread adverse health affects ranging from severe respiratory affects, reactive airway inflamation, burning & blood shot eyes, burning nasal passages and throat, strange taste in mouth, metallic/rubber tasting, naseau, extreme fatigue and malaise, cognitive defecits to name some of the symptoms. Northeast Clean Air Coalition, Our state senators & representatives, Willem Jewett, Claire Ayer & Harold Giard and other Env. Groups working on this issue have called for an "IMMEDIATE HALT OF IP TIRE BURN TEST W/OUT ESP POLLUTION CONTROLS". The IP Tire Burn is poised to continue Monday, 11/13/06 and we need your help to STOP THE IP TIRE BURN BEFORE IT RESUMES Monday morning 11/13/06 to protect the children and citizens of VT, NY and this entire region from this knowingly intentional outragous act by IP & NY DEC to recklessly and unconsci onable harm citizens w/out their consent or due representation. We have contacted the VT DPH Commissioner, Sharon Moffat and VT DEC Commisioner Jeff Wennberg and the Governor through Jeff Wennberg on Thursday 11/9 & Friday 11/10 and informed them of the serious adverse health affects that are directly resulting from IP's Tire Burn w/out Industry Standard ESP Pollution Controls and they have failed to acknowledge and/or act to protect the citizens of Vermont an d this region and allowed IP to continue with the UNSAFE Tire Burn. Consequently our state Senators Jewett, Ayer & Giard have authored a letter to the VT Governor Jim Douglas, VT DPHCommissioner

Sharon Moffat, VT DEC Commissioner Jeff Wennberg and VT AG William Sorrell confirming the above and calling for the Immediate Halt of the IP Tire Burn to protect citizens across the region (see letter below). Also, see Tom Vanacore's confirmation of regulatory authority of the Dept. of Health w/the Governor t o call an immediate halt of the IP Tire Burn that is causing wide spread adverse health and environimental affects. We need your immediate help to Stop the IP Tire Burn before any more harm can occur and to call for independent testing of what is being e mitted from this facility which is the largest polluter in the entire region at over 615,000 pounds of Air, Water, Land Toxics Emissions/Discharges annually per their 2004 EPA TRI reportings with total annual pollution in the billions of pounds. Please ta ke whatever action possible to aid this urgent effort. Please contact us as soon as possible to report your progress, efforts, etc. We thank you so very much for your help and support in this most urgently needed time.
[1] The IP Ticonderoga Plant operates at approximately 75% removal of overall particulates when other plants show better than a 95% efficiency rate. The 2004 total Air, Water and Land Toxics Emissions were 615,398 pounds; (452,144 pounds air toxics emissio ns, 106,928 pounds surface water toxics discharges and 56,325 pounds of toxic on

- site landfills) according to the EPA's Toxics Release Index database ( <> www.epa.gov/tri). Approximately 2000 pounds of toxic pollutants released daily and a 50% increase in 20 02 Air, Water and Land Toxics Emissions of over 400,000 pounds (341,061 pounds in air toxics emissions, 66,294 pounds surface water toxics discharges).

[2] International Paper's Website / Environment Mission Page states:( <> http://www.internationalpape r.com/Our%20Company/Environment/index

.html ) "An essential part of our business strategy is to make products in a safe and healthful workplace, to manage natural resources wisely, and to continually improve our environmental performance. We are committed to removing the conditions and behaviors that cause personal injury or environmental impact. At International Paper, we believe an important measure of our success is our performance as neighbors, employers and environmental stewards, and for that reason w e remain dedicated to making continuous improvement."

Very Best, BJ Ernst, Executive Director Northeast Clean Air Coalition PO Box 95 Vergennes, VT 05491 802

- 759

- 2259 Phone/Fax email: <> bernst@gmavt.net, <> necac1@yahoo.com

************************************ November 12, 2006
James Douglas Governor, State of Vermont 109 State Street Montpelier, VT 05609 Jeffrey Wennberg <> jeff.wennberg@state.vt.us Commissioner, Vermont Department of Environmental Conservation 103 South Main Street, 1 SouthWaterbury, VT 05671

Sharon G. Moffatt <> smoffatt@vdh.state.vt.us Deputy Commissioner, Vermont Department of Health 108 Cherry Street P.O. Box 70 Burlington, VT 05401
Re: International Paper

- This is not a "test burn" Dear Governor Douglas, Commissioner Wennberg, and Deputy Commissioner Moffatt: International Paper has said that they need to test burn tires in order to determine whether additional pollution control devices are needed. While many of us have known it for several years, the past week has demonstrated convincingly that this is not a test. This is not a test because the test has already been conducte d by the EPA. The EPA's October 1997 report entitled "Air Emissions >From Scrap Tire Combustion" tested air emissions from 22 industrial facilities as well as from a specially designed tire incinerator. The EPA report demonstrated conclusively that emiss ions of zinc and particulates increase dramatically when tires are burned. While the report is generally supportive of tire burning its authors emphasize many times that increased emissions are controllable with electrostatic precipitators.

This is not a test because the protocol does not require testing for fine particulates (PM 2.5) even though these pollutants have been identified as causing health problems. If this were a test that was being used to protect our health, the protocol would not ignore pollutants with known health risks This is not a test because International Paper is not running the boiler at full capacity. We understand that the boiler will not exceed 748 MMBtu/hr during the so

- c alled test even though it is rated to run at 855 MMBtu/hr. If this were a test, air emissions would be sampled at fullcapacity as opposed to 12.5% below capacity.

This is not a test because the tires being burned during the test have been cleaned o f metal and other impurities. If this were a test, the material being burned during the test would be identical to what IP proposes to burn after the test.
Despite these favorable conditions, the test has dramatically failed. On November 9, while bu rning tires at one ton per hour (just one

- third their proposed rate of three tons per hour) International Paper exceeded its permit limit of 0.10 lbs/mmbtu. More importantly, even at this early stage, we have been receiving numerous health complaints rela ted to the tire burn.
Frankly, we are not satisfied with the State's reaction to these developments. Respectfully, we would ask you to take the following steps immediately: 1) Make it clear to Vermonters and to IP through explicit public statements that the so

- called test has failed and demand that no additional tires are burned at the Ticonderoga Mill unless and until appropriate pollution control devices are installed. Our constituents should no longer be used as subjects of this experi ment. Their health is simply more important than IP's profit. 2) Send Health Department employees out to personally and individually review each and every health complaint whether or not that complaint results in a visit to a hospital or doctor. Car eful analysis of these reports may be important in the State's continuing effort to stop IP's plan to burn tires. 3) On an emergency basis, enact air quality standards for at least zinc oxide if not also for PM 2.5. The zinc oxide standard has bee n fully reviewed by the agency and is scheduled for implementation in the very near future. We can think of no valid reason that the zinc oxide standard atleast was not in place prior to the so

- called test burn.

Sincerely,
Representative Will em Jewett State Senator Claire Ayer State Senator Harold Giard
Cc: Attorney General William Sorrell United States Senator Patrick Leahy United States Senator

- elect Bernard Sanders United States Congressman

- elect Peter Welch

********************************** To: <> jeffwennberg@state.vt.us Cc: <> smoffat@vdh.state.ma.us ; <> bernst@gmavt.net Sent: Sunday, November 12, 2006 11:39 AM Subject: Reactive Airway Dear Sirs, I'm e

- mailing to report to you recent events which st em from the IP INTERNATIONAL PAPER tire burn that need reporting. Late Tuesday afternoon I experienced what appeared to resemble an Asthmatic Attack. The problem, I've never had asthma before and I was at the point which required one to gasp for air. I was able to treat this episode by closing doors and sit in an upright position. As the week progressed my voice became raspy, I had a foul/strange taste in my mouth and my chest maintained a profound level of weight (making it very hard to breath). The ironic piece to all of these events are that I just had a physical one and a

- half weeks ago with reports of a clean bill of health. I had thisphysical done at the request of my doctor as the last visit to the office

was recorded ten years ago. On Saturday, I left the house at 9:15 am and about three hours later my breathing improved. I remained out of town for the remainder of the day. At 9:00 pm I came back home from the Burlington area and after being in the house for an hour and a

- half I beg an to experience the foul/strange taste, raspy voice, and heavy chest with problems taking air in again. At this time I went to the Porter Hospital emergency room and was treated for REACTIVE AIRWAY. My problem with all of this is now I'm requiring Alb uterol Inhalers in order to breath and having to purchase and use Hepa Air Filtration systems within my home, in order to remain in my home and be able to breath. Sincerely, LL Shoreham Vt 05770
************************************* To: <> bernst@gma vt.net Sent: Friday, November 10, 2006 8:42 AM Subject: Re: Health Advisory Emergency

- IP Tire Burn

- People Reporting Adverse Healt...
Tuesday night 11/7/06 the smell was so bad, my daughter's eyes started to water, her son Robbie (7yrs) had an astm atic attack, we live in Bridport . I, l called the IP plant imediately, and think everybody should when they smell the plant, also last night the 11/9/06 the smell was very bad. My daughter who lives in Middlebury also called dr. Mayer, who advised Robbies Astma

- medicine. They will NOT be able to come visiting till the test is over. !!! I personally didnt think it was going to be this bad./BRl/Bridport/VT

************************ ****** 1,2,3 John V. Faraci, Chairman and CEO & David Struhs, VP of Environmental Affairs William Waters, Director of SalesInternational Paper

6420 Poplar Avenue Memphis, TN 38197 901

- 419

- 7000, 901

- 419

- 4633

- Fax <> john.faraci@ipaper.co m <> david.struhs@ipaper.com <> William.waters1@ipaper.com <> http://www.internationalpaper.com
4.. Christopher P. Mallon, Plant Manager International Paper, 568 Shore Airport Rd., <> chris.mallon@ipaper.com Ticonderoga, NY 12883, 518

- 585

- 6761, <> http://www.internationalpaper.com

Additional Websites & Web links:

. <> http://www.lesspollution.org

- People for Less Pollution Website

. <> http://www.lesspollution.org/facts.html

- Fast Facts About IP's Proposed Tire & Sludge Burn. <> http://www.vpirg.org/campaigns/environmentalHealth/iptirefacts.php

- Tire Incineration Fact Sheet, VPIRG <> http://www.lesspollution.org/newsletter

- 1.html

- PLP Newsletter 9/05 <> http://www.lesspollution.org/ip_history.html

- IP Ti's E nvironmental Record: <> http://www.lesspollution.org/ip_history.html Additional Governmental & Agency Contacts: A. New York: 1. Gov. George E. Pataki, 518

- 474

- 1041/518

- 474

- 1513

- Fax, Exec. Chambers, State Capital, Albany, NY 12224, <> www.ny.gov/ governor 2. Sen. Hillary Rodham Clinton, 476 Russell Senate Office Building, Washington, DC 20510, 202

- 224

- 4451, 202

- 228

- 0282

- Fax, <> www.clinton.senate.gov/contact, 3. Sen. Charles E. Schumer, 313 Hart Senate Building, Washington, DC 20510 202

- 224

- 6542, 202

- 228

- 3027

- Fax, <> www.senate.gov/~schumer/B. EPA & NY Dept. of Environmental Conservation

1. Stephen Johnson, Administrator, EPA, 1200 Pennsylvania Ave. NW, Washington, DC 20460, 202

- 564

- 4700,202

- 501

- 1450

- Fax, <> johnson.stephen@epa.gov 2. Alan Steinberg, EPA Region 2 Administrator, 290 Broadway, 25th Flr., New York, NY 10007

- 1866, 212

- 637

- 5000/3901

- Fax, <> steinberg.alan@epa.gov 3. Robert W. Varney, Region 1 Administrator, New England, 1 Congress St., Ste 1100, Boston, MA 02114

- 2023, 617

- 918

- 1111,617

- 918

- 0101

- Fax, <> varney.robert@epa.gov 4. Denise M. Sheehan, Commissioner, Dept. of Environmental Conservation, 625 Broadway, Albany, NY 12233, 518

- 402

- 8540/8541

- Fax, <> dmsheehan@gw.dec.state.ny.us 5. Thomas W. Hall, Regional Permit Administrator, NY DEC Region 5, Division of Environmental Permits, Route 86, Raybrook, NY 12977

- 0296, 518

- 897

- 1234, 518

- 897

- 1394

- Fax C. Vermont: 1. Governor Jim Douglas, 109 State Street, Pavilion, Montpelier, VT 05609

- 0101, 1

- 800

- 649

- 6825 (VT Only), 802

- 828

- 3333, 802

- 828

- 3339

- Fax, <> www. vermont.gov/governor/contact.html 2. Sen. Patrick J. Leahy, 433 Russell Senate Office Bldg., Washington, DC, 20510, 202

- 224

- 4242, 1

- 800

- 642

- 3193 (VT Only) <> senator.leahy@leahy.senate.gov 3. Sen. James M. Jeffords, 413 Dirksen Senate Office Bldg, Washington, DC 20510, 202

- 224

- 5141, 1

- 800

- 835

- 5500 (VT Only) , Jeffords.senate.gov/contact.html 4. U.S. Rep. Bernie Sanders, 2233 Rayburn H.O.B., Washington, DC 20515, 202

- 225

- 4115, 202

- 225

- 6790

- Fax, 1

- 800

- 339

- 9834 (VT Only), <> http://bernie.house.gov/const_serv/comments.asp 5. Jeffrey Wennberg, Commissioner, Dept. of Environmental Cons ervation, 103 South Main St., One South Building,Waterbury, VT 05671

- 0401, 802

- 241

- 3808, 802

- 244

- 5141

- Fax,

<> jeff.wennberg@state.vt.us

****************************************