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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.com] 

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

To: Garnett, Kim 

Cc: Bivins, Dan; andreag@cooperenvironmental.com; kragp@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 mind 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 facility 

averaged approximately 8 percent moisture content and 140 degree F while the multi-metals CEMS was being 

operated. However, Pall Corporation has assured EPA that trial tests on its CEMS demonstrate that the unit can 

operate reliably at moisture contents above 40 percent. The only document in the record produced by EPA to 

support this statement is one email exchanged between Pall and EPA. EPA failed to consider the fact that Pall, 

which manufactures the multi-metals CEMS, has a financial interest to overstate the CEMS capabilities. No 

data or objective evidence exist in the record to demonstrate the Xact multi-metals CEMS can operate at 

moisture contents at or above 40 percent. 

2- The Xact Muli-Metals CEMS is identified in the Statement of Basis as a system that uses reel-to-reel filler 

tape sampling technology followed by X-ray fluorescence analysis of metals in the deposit. The Statement 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. The 

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 incinerators Mcluding the Eli Lilly incinerator employ wet 

scrubbers as their pollution control equiprhent or a combination of wet scrubbers and baghouses. The off 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 the 
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amount of metals in the emissions stream. Unlike these wet scrubber systems, Veolia operates a dry pollution 

control system on Units 2, 3 and 4 of its Sauget facility. Dry systems are unique and to my knowledge the only 

other exclusively dry system in the United States is the Clean Harbors incinerator in Kimball, 

Nebraska. Veolia's dry pollution control systems operate at much higher moisture and temperature ranges than 

wet scrubber systems. The Xact multi-metals CEMS has never been demonstrated to successfully operate in the 

high moisture and high temperature environment presented 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 say a few sentences about how well it wokrd at Army? Any 

maintenance issues, etc.? 

Dan 

EPA’s statements that the U.S. Army has successfully installed and evaluated a multi-metals CEMS on one of 

its hazardous waste incinerators, and that a multi-metals CEMS is an acceptable option in the MATS rule 

(Statement of Basis at 24) are not correct. A hypertext search of the MATS rule did not show any reference to a 

multi-metals CEMS. Additionally, while it is correct 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 raining. 

I will have a response to the comment when you return 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 holiday for us. Enjoy your weekend! Hope not raining now in Portland! 

Dan 

Dan Bivins 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Measurement Technology Group 

919-541-5244