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 started 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 agencies 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 trigger 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 taken 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 to 
document 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 from 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 direction 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 last 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 the 
southerly 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 Vermont 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 need 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 Safety:

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 

where 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 Tuesday 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 Spin 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 use 
executive power to stop the tire 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 updates 

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 test 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 this 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 been 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 testing 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 severe 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 power 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 

early 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: Technical 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 as 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 Burn 
without 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: <>Wennberg, 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, Vermont
Ambient 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 analyzed 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 particulate matter speciation with 
XRF, 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 distribution 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>Dalmasse, 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 IP 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 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.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 Safety:

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 there 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 0.10lbs/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 ton 
increments to ensure stable boiler operations. During the one-week rampup and shake down period, 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 onsite 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 

week 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 conditions (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 

the 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 that "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 

Carman, 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 old 
inefficient boiler will generate over regulation 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 composition 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 units, 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 amend 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, and 
yet IP does not propose to revise its boiler maximum fuel rate of 855 

MMBtu/hr to 748 MMBtu/hr.

IP has failed to provide representations 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/iptireburn.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 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>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 an immediate halt to this public 

health endangering test. Please respond as soon as possible in the 
interest 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.us
Re: International Paper Ticonderoga 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 there 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 that 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 testing 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 comply 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 

observers 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 pollutants 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 today. 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 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. Because of the delay with the wood bark 

feeding 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 before 
the 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 out 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 went 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 beginning 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 fuel (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 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 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 baseline particulate test, IP introduced 

tire derived fuel (tdf) into solid the 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 before the 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 out the first particulate test with tdf in the mix 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 went well and they are satisfied it is an 

accurate number.

Justin

Justin Johnson

Communications Coordinator

Vermont Department of Environmental Conservation

ph: 802 241 3803

cell: 802 236 4030

email: <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 Tire 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 caused 
widespread

adverse health affects throughout VT, NY and the region. IP has exceeded

all pollution limits for particulates and ran 40 hours at over federal &

state 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 unconscionable 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 and 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 DPH 
Commissioner

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 to 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 emitted 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 take 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 emissions, 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 2002

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.internationalpaper.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 we 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 South
 Waterbury, 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 conducted 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 emissions 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-called test even though it is rated to run at 855

MMBtu/hr. If this were a test, air emissions would be sampled at full
capacity as opposed to 12.5% below capacity.

 This is not a test because the tires being burned during the test have

been cleaned of 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 burning 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 related 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 experiment. 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. Careful 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 been 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 at
least was not in place prior to the so-called test burn.

 Sincerely,

 Representative Willem 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 stem 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 this
physical 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 began 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

Albuterol 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@gmavt.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 astmatic 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 Sales
 International Paper

 6420 Poplar Avenue

 Memphis, TN 38197

 901-419-7000, 901-419-4633-Fax

<>john.faraci@ipaper.com

<>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

Environmental 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 

Conservation,

103 South Main St., One South Building,
 Waterbury, VT 05671-0401, 802-241-3808, 802-244-5141-Fax,

<>jeff.wennberg@state.vt.us

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