1 

### Ogulei, David

From: Garnett, Kim Sent: Wednesday, October 08, 2014 1:28 PM To: Ogulei, David Subject: FW: FYI

From: John Cooper [mailto:jacooper@cooperenvironmental.c om]

Sent: Thursday, May 23, 2013 3:00 PM

To: Garnett, Kim

Cc: Bivins, Dan; andreag@cooperenvironmental.com; krag p@cooperenvironmental.com Subject: RE: FYI

Thanks Kim – I really appreciate the opportunity to respond to these comments. Thanks, John

From: Garnett, Kim [ mailto:Garnett.Kim@epa.gov ] Sent: Thursday, May 23, 2013 9:57 AM To: John Cooper Cc: Bivins, Dan Subject: RE: FYI

John,

Here are two additional questions if you wouldn’t m ind taking a look at them also.

Thanks,

Kim

1 - 

### The Statement of Basis states in subsection 4.0(D)( c): “Eli Lilly's stack gases at the Tippecanoe faci lity averaged approximately 8 percent moisture content a nd 140 degree F while the multi-metals CEMS was bei ng operated. However, Pall Corporation has assured EPA that tria l tests on its CEMS demonstrate that the unit can operate reliably at moisture contents above 40 perc ent. The only document in the record produced by E PA to support this statement is one email exchanged betwe en Pall and EPA. EPA failed to consider the fact t hat Pall, which manufactures the multi-metals CEMS, has a fin ancial interest to overstate the CEMS capabilities. No data or objective evidence exist in the record to d emonstrate the Xact multi-metals CEMS can operate a t moisture contents at or above 40 percent.

2- The Xact Muli-Metals CEMS is identified in the S tatement of Basis as a system that uses reel-to-ree l filler tape sampling technology followed by X-ray fluoresc ence analysis of metals in the deposit. The Statem ent of Basis represents that this is the only multi-metals CEMS technology currently commercially available. Pall Corporation is identified in the Statement of Basis as the marketer for the Xact multi-metals CEMS. T he Statement of Basis discusses the use of a Xact CEMS at the former Eli Lilly incinerator. Eli Lilly's incinerator and Veolia's Unit 3 are not comparable. Most incin erators Mcluding the Eli Lilly incinerator employ w et scrubbers as their pollution control equiprhent or a combination of wet scrubbers and baghouses. The o ff gases from incinerators using wet scrubbers have similar moisture and temperature ranges. The suppliers of die Xact multi-metals CEMS claim that the Xact analyzes the off gas emitted from an incinerator to determine th e2 

### amount of metals in the emissions stream. Unlike t hese wet scrubber systems, Veolia operates a dry po llution control system on Units 2, 3 and 4 of its Sauget fa cility. Dry systems are unique and to my knowledge the only other exclusively dry system in the United States i s the Clean Harbors incinerator in Kimball, Nebraska. Veolia's dry pollution control systems o perate at much higher moisture and temperature rang es than wet scrubber systems. The Xact multi- metals CEMS has never been demonstrated to successf ully operate in the high moisture and high temperature environment pres ented by Unit 3.

From: Bivins, Dan Sent: Thursday, May 23, 2013 11:05 AM To: John Cooper Cc: Garnett, Kim Subject: RE: FYI

Here’s another one. Is this one true? Could you s ay a few sentences about how well it wokrd at Army? Any maintenance issues, etc.?

Dan



### EPA’s statements that the U.S. Army has successfull y installed and evaluated a multi-metals CEMS on on e of its hazardous waste incinerators, and that a multi- metals CEMS is an acceptable option in the MATS rul e (Statement of Basis at 24) are not correct. A hypertext search of the MATS rule did not show an y reference to a multi-metals CEMS. Additionally, while it is corre ct that the U.S. Army purchased and installed three Xact units, none have ever been used for compliance with Subpart EEE.

From: John Cooper [ mailto:jacooper@cooperenvironmental.com ] Sent: Thursday, May 23, 2013 10:49 AM To: Bivins, Dan Subject: RE: FYI

Dan, Hoping is nice but reality is sometimes different - it rained all day yesterday and is currently rain ing.

I will have a response to the comment when you retu rn on Tuesday. John

From: Bivins, Dan [ mailto:Bivins.Dan@epa.gov ] Sent: Thursday, May 23, 2013 7:00 AM To: John Cooper Subject: FYI

Will be on furlough tomorrow and Monday is a holida y for us. Enjoy your weekend! Hope not raining no w in Portland!

Dan

Dan Bivins U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Measurement Technology Group 919-541-5244