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Ogulei, David

From: Krag Petterson [kragp@cooperenvironmental.com]

Sent: Thursday, July 18, 2013 1:30 PM

To: Ogulei, David

Cc: 'John Cooper'; andreag@cooperenvironmental.com

Subject: FW: 

David, 

I wanted to add a little clarification on my response to your first question. We would be able to deliver a unit on site 

within 4 to 5 months then we should allow 2 to 3 months to get the RATA scheduled and completed. 

Please don’t hesitate to contact me if you have any questions. 

Best Regards, 

Krag 

Krag Petterson 

Vice President 

Cooper Environmental Services, LLC 

10180 SW Nimbus Ave Ste. J6 

Portland, OR 97223 

503-670-8335 

From: Krag Petterson [mailto:kragp@cooperenvironmental.com] 

Sent: Wednesday, July 17, 2013 3:32 PM 

To: 'Ogulei.David@epa.gov' 

Cc: 'andreag@cooperenvironmental.com'; 'John Cooper' 

Subject: 

Mr. Ogulei,

Andrea asked me to provide you with some responses to the questions you sent to her in your email dated June 21, 

2013. My responses to each question are given in red. In addition I have attached several files in response to these 

questions as well. 

I am particularly interested in receiving an update on the following areas: 

1. Commercial availability of the Xact multi-metals CEMS. 

The Xact CEMS is available commercially from Cooper Environmental Services, LLC. (CES) Pall Corporation 

discontinued its license in early February of this year and since that time CES has been marketing and

manufacturing both the Xact 625 and Xact 640 and 645 (CEMS models). 

Xact 640 (Multi-Metals CEMS) – All CEMS sales have been in the United States. 

Eli Lilly – 1 unit 

US Army – 3 units 

CES – This demonstration unit has been used for testing sponsored by various organizations including U.S. EPA, 

Electric Power Research Institute (EPRI) and Eli Lilly. 

Xact 620/625 

Korea – 6 units purchased by National Institute of Environmental Research 
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China – 9 units purchased by various Environmental Monitoring Centers 

Canada – 8 units Ontario Ministry of Environment, Environment Canada, Quebec Ministry of Environment, 

University of Toronto, University of Dalhousie, and a smelting facility 

New Zealand – 1 unit – secondary lead smelter 

Austraila 1 unit – Queensland EPA 

United States 3 units – U. Mass., Missouri DEQ, U.S. EPA 

We have known competition for the ambient market in China from FPI and Skyray (both Chinese companies). 

We have also heard that FPI produces a multi-metals CEMS but cannot confirm this. 

We have no known competition outside of China. 

2. Applicability/feasibility/reliability of the Xact multi-metals CEMS for measuring emissions from heterogeneous 

waste streams. 

The Xact and the filter chemistry utilized by the Xact have demonstrated the ability to make 

measurements in wide variety of stack conditions. Testing with the Xact and its filter 

chemistry has occurred on stacks burning many different fuel types including coal (sub-bit, 

lignite and bituminous), natural gas, and diesel fuel and testing has occurred at facilities 

with different pollution controls like ESP's, baghouses, and wet scrubbers. The Xact has 

been tested on facilities with stack temperatures ranging from 100 to 450 degrees Fahrenheit 

and ranging in moisture content up to at least 20%. In addition the Xact has demonstrated 

accuracy in the presence of a wide range chemical species likely to be present in stack 

effluent. 

One of the strengths of the Xact is that the sample collection is separated from the X-ray 

analysis. This means that the more sensitive components of the analysis system are never 

exposed to stack effluent. In addition because the Xact collects a sample for a defined 

length of time (for example 

15 minutes) this means that the filter trapping chemistry is refreshed with every sample 

eliminating the problems with the chemistry becoming spent over time. Also the Xact employs 

sample dilution prior to the filter trapping allowing many of the stack gas components and 

the dew point to be diluted to their optimal ranges. Finally, we would recommend dynamic 

spiking procedures in performing RATA's, similar to those used by Eli Lilly in their 

alternative monitoring petition. Dynamic spiking allows the Xact to be challenged by a known 

concentration of metals in the presence of potentially interfering components from the stack 

gas. 

I’ve attached two files with details on the range of stack conditions over which the Xact has 

been tested. 

1) Method 301 Report.pdf – please see section 7 

2) Pall Comments on the Secondary Lead Smelter MACT Rule.pdf – these give additional 

details on places the Xact has been tested. 

3. Case studies documenting application and/or deployment of the Xact multi-metals CEMS. 

Please see the files above. In addition I would add the following documents listed below. 

1) Yanca-2006 - Paper published in the Journal of the Air and Waste Management Association 

documenting the Method 301 validation of the Xact. 

2) EP-D-07-026 Final report and Appendix A.pdf – paper documenting the Xact’s performance during an 

EPA sponsored Small Business Innovative Research grant. The RATA procedures used at Eli Lilly were 

performed on a coal fired source. 

3) Xact 625 ETV Report.pdf – this was study was done on an ambient unit but demonstrates the accuracy 

of the technology 
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4) Xcem.pdf – an Army Corps of Engineers study of the Xact’s performance on Army’s hazardous waste 

incinerators. 

5) Feasibility of using the Xact Multi-metals CEMS as a Mercury Monitor on Coal Fired Power Plants.pdf – 

presentation given at the EUEC conference in 2011 and documents our comparison with Method 30B 

for mercury. 

4. List of locations/facilities where the Xact multi-metals CEMS is currently deployed and operating for any reason.

I’ve listed the facilities were the Xact CEMS was deployed 

1. Eli Lilly’s Tippecanoe Laboratories, Lafayette IN – Deployed and operated for 6 years. The facility is 

under new ownership and the Xact is no longer operated. 

2. U.S. Army – Tooele UT munitions test furnace – It operated periodically at this facility as the U.S. Army 

tested procedures for burning different types of munitions. 

3. U.S. Army – Tooele, UT production furnace. The Xact was installed at this facility but was never 

operated because regulations were never required for it. 

4. U.S. Army – Crane, IN production furnace. The Xact was installed at this facility but was never operated 

because regulations were never required for it. 

5. How beryllium emissions are typically handled given that the Xact multi-metals CEMS cannot quantify beryllium.

Eli Lilly was only client that utilized the Xact CEMS for compliance purposes it handled the beryllium issue as 

follows (quoted from Lilly’s AMP) 

“Because the XACT is incapable of measuring beryllium (Be), Lilly has developed a default value for beryllium emissions. 

Fortunately, beryllium is a scarce element that is not used in Lilly pharmaceutical manufacturing processes. Lilly has 

examined all its manufacturing processes and associated process construction materials (e.g. alloy steels) and found no 

indication that beryllium should be present. Therefore, Lilly believes that a conservatively calculated default value for 

beryllium is technically defensible. 

Trace levels of beryllium are possible in raw materials and ground water. Lilly has sampled its liquid waste and found only 

sporadic “hits” of beryllium at levels close to the detection limits. Lilly has also done some limited sampling of plant trash, 

some of which might be processed in the solid-liquid incinerator, and some low-levels of beryllium were reported. For the 

purposes of calculating a conservative default emission concentration, Lilly has assumed that all liquid and solid wastes 

fed to the solid-liquid incinerator contain Be at the maximum levels detected: 1.0 ppm in the solid waste and 0.01ppm in 

the liquid wastes. The default emission concentration was then calculated using the maximum waste feed rates from the 

CPT plan, and an LVM system removal efficiency (SRE) of 98% (which is a factor of two less than the design SRE of 99% 

and a factor of 20 less than the SRE of 99.9% obtained during the CPT of another Lilly incinerator with a virtually identical 

scrubber system). The resulting value was just over 1 ug/dscm. To be more conservative, Lilly has chosen 2 ug/dscm as a 

default value. Therefore, a value of 2 ug/dscm will be added to the measured LVM emission before comparison to the 

emission standard limit. If the CPT data or any other evidence indicates the default value is not appropriate, it will be 

adjusted accordingly.”

6. Estimated timeline for deployment of the Xact multi-metals CEMS at an existing facility, i.e., from order date to 

operation. What are the potential challenges? 

We believe that a 9 month time line is sufficient and includes manufacturing, shipping installation and RATA 

testing. 

Krag Petterson 

Vice President 

Cooper Environmental Services, LLC 

10180 SW Nimbus Ave Ste. J6 

Portland, OR 97223 
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503-670-8335