To The New York Department of Environmental Conservation:

Michael J. McMurray,
NYSDEC Region 5 Headquarters
1115 NYS Route 86, P.O. Box 296,
Ray Brook, NY 12977-0296

Technical Comments on the Revised Application to Modify International Paper, Ticonderoga Mill's Title V Permit to Conduct a Two-week Tire-Derived Fuel trial.

Submitted by the Board of People for Less Pollution

 1.  If IP-Ti wants to burn dirty fuels (such as tire-derived fuel (TDF) or sludge) they should install equipment to remove fine particulates, in all likelihood an electrostatic precipitator (ESP). A wet ESP would have particular advantages since (1) it is smaller than a dry one and (2) IP-Ti already has a wastewater treatment plant (WWTP) and therefore would have a means to treat the ESP's effluent. We believe the installed cost of such a unit to be very roughly $5 million, which, for a savings of $2 to $3 million per year, would provide a good rate of return on the investment. We know that IP has quoted various numbers concerning the cost of an ESP, but we are unaware of their having actually obtained a cost estimate from a manufacturer of the equipment.  Several years ago, a quote of about $1 million uninstalled cost was obtained for a wet ESP (for an application with a similar air flow rate, at a different company). This knowledge makes us confident that the cost of an ESP is in the millions of dollars (but certainly not nearly $10 million).  An ESP is a particularly good choice when burning TDF, because the zinc oxide is homogeneously dispersed in the rubber and hence has significant potential to produce the fine particulates that are now know to be much more harmful to human health than the larger fly ash. In fact, installing an ESP on IP-Ti's Power Boiler, whether or not they choose to burn TDF or sludge, would be of significant benefit to the citizens of New York and Vermont, to Lake Champlain, and to our environment.

2. The revised permit application does not contain an adequate discussion of how burning TDF will affect PM 2.5 emissions and how PM 2.5 emissions will be monitored. Wet scrubbers have high particulate removal efficiencies for particles over 10 microns, but only about 50% removal of particles in the 0.1 to 1 micron range (this is smaller than fly ash, in the size range of tobacco smoke).  These fine particulates, known to be significantly more hazardous to human health, can, however, be efficiently removed by electrostatic precipitators (ESP's). (Note that the efficiencies we give here -- from Perry's Chemical Engineering Handbook and other sources -- are consistent with the EPA calculation discussed in the subsequent section of the permit application,"Wet Scrubbers").  Data on particle size and a metals analysis of particles of different size ranges coming out of the stack, although difficult and expensive to do, would be very helpful.

3. The permit does not specify the grade of tire-derived fuel that could be burned during the test.  IP is planning to burn a higher-grade tire-derived fuel during the test burn which does 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. Because IP lacks proper equipment for feeding TDF to the power boiler, the TDF IP proposes to burn during the test burn will have 99.5% of the tire bead and cord wire removed. If the plant is granted permission to burn tires on a regular basis IP will burn a TDF with only 95% of the tire bead and cord wire removed. The higher-grade TDF burned during the test burn will have different energy, ash, zinc, and metal contents than the lower-grade TDF and the results of the test burn will not be directly comparable to the operating conditions in the plant  or the magnitude of pollutants released from the plant if IP is granted permission to burn TDF on a regular basis.

Technical Comments on The IP Draft Permit to Burn Tires

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