### Re: Multi-metal CEMS Jeff Ryan to: David Ogulei, Sarah Marshall 09/25/2012 03:10 PM Cc: Dan Bivins, Charles Hall, Sarah Marshall I'm still information collecting, but here's a bit of an update. I have spoken with John Cooper (inventor) and Doug Barth (licencer). The technology has been at Lily for close to 6 years now, and to the best of their knowledge, chugging happily along. I have contacted Rick Lambert @ Lily to see if he would be willing to speak with me. He is. I then pressed my luck to find out if I could add you guys to the call. I haven't heard back on that. Is that something you guys would want to do? John Cooper let me know that DoD has 3 systems that they bought for some munitions incineration. They don't know too much about that. That would probably not be a great source of info anyway, as the system is not likely used regularly and is operated more as a process monitor. As part of Lily's use of the Multi-Metals monitor, they prepared a number of documents that are now posted on the OAQPS Methods site. I've provided links below. Look at the OTMs starting with 16 I believe. John and Doug would be happy to speak with you all as well. I also didi confirm that their system will work in a 40% moisture environment. Let me know if you want to be on the call with Lily. If you can't and have specific questions, please let me know. Jeff

http://www.epa.gov/ttn /emc/monitor.html#metals http://www.epa.gov/ttn/emc/prelim.html

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__________________________________________________ _ Jeff Ryan U.S. Environmental Protection Agency Office of Research and Development National Risk Management Research Laboratory Air Pollution Prevention and Control Division Air Pollution Technology Branch 109 T.W. Alexander Drive Mail Drop E305-01 Research Triangle Park, NC 27711 (919) 541-1437 (919) 541-0554 FAX "And all this science, I don't understand." "It's just my job 5 days a week" Elton John - Rocket Man

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__________________________________________________ _ David Ogulei 09/18/2012 02:33:16 PM Let's see if Dr. Cooper k nows of any additional d...
From: David Ogulei/R5/USEPA/US To: Jeff Ryan/RTP/USEPA/US@EPA Cc: Dan Bivins/RTP/USEPA/US@EPA, Charles Hall/R5/USEPA/US@EPA Date: 09/18/2012 02:33 PMSubject: Re: Multi-metal CEMS Let's see if Dr. Cooper knows of any additional deployments. I'll see if I can find any technical reviews on the multi-metal CEMS in the MATS rule docket. Thanks for your help with this.
-David Jeff Ryan 09/18/2012 12:25:46 PM I'm going to meet with John and Doug tomorrow...
From: Jeff Ryan/RTP/USEPA/US To: Dan Bivins/RTP/USEPA/US@EPA, Cc: David Ogulei/R5/USEPA/US@EPA, Charles Hall/R5/USEPA/US@EPA Date: 09/18/2012 12:25 PM Subject: Re: Multi-metal CEMS I'm going to meet with John and Doug tomorrow and will find out more. I just didn't know if there was a consent decree or anything that required additional installations

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__________________________________________________ _ Jeff Ryan U.S. Environmental Protection Agency Office of Research and Development National Risk Management Research Laboratory Air Pollution Prevention and Control Division Air Pollution Technology Branch 109 T.W. Alexander Drive Mail Drop E305-01 Research Triangle Park, NC 27711 (919) 541-1437 (919) 541-0554 FAX "And all this science, I don't understand." "It's just my job 5 days a week" Elton John - Rocket Man

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__________________________________________________ _ Dan Bivins 09/18/2012 12:43:49 PM Jeff and David, I'm kinda like you Jeff, don't kno...
From: Dan Bivins/RTP/USEPA/US To: Jeff Ryan/RTP/USEPA/US@EPA Cc: David Ogulei/R5/USEPA/US@EPA, Charles Hall/R5/USEPA/US@EPA Date: 09/18/2012 12:43 PM Subject: Re: Multi-metal CEMS Jeff and David, I'm kinda like you Jeff, don't know of other systems running at this time. I know they were evaluated at the Army incinerator and at Oak Ridge but don't know if any installed and operating except for Lilly. Let me know what Cooper says.
DanJeff Ryan 09/18/2012 08:41:05 AM Hi David Hopefully I can help you out. I am VER...
From: Jeff Ryan/RTP/USEPA/US To: David Ogulei/R5/USEPA/US@EPA Cc: Charles Hall/R5/USEPA/US@EPA, Dan Bivins/RTP/USEPA/US@EPA Date: 09/18/2012 08:41 AM Subject: Re: Multi-metal CEMS
Hi David Hopefully I can help you out. I am VERY familiar with the Veolia facility and Region efforts to get them to monitor emissions. Let me preface this by saying that there really hasn't been the same push behind multi-metal CEMS as there has been for mercury. As a result, multi-metals CEMS are not as widely applied. However, they are an accepted option in for metals emission compliance in the utility MATS rule. To the best of my knowledge, there's really only one multi-metals CEM system - The Cooper XRF system that is now licensed by PALL Corporation. I'm convinced that there are more systems installed out there than the Eli Lily system, but I just don't know what they are. As for as reports, literature, publications, especially recent, I have not run across anything other than the Eli Lily material. Your timing is good though. Dr. Cooper is in RTP this week and I will be meeting with him tomorrow. I will certainly get an update. What I do know is that Dr. Cooper has been in regular content with EPA to further refine a number of his procedural approaches and documents. Most recently, he has worked to establish a formal NIST Traceability document for his Quality Aerosol Generator (QAG) that is used for verifying emissions monitoring data quality. Have you spoken to Dan Bivins in OAQPS? Dan has been the one in OAQPS that has been responsible for the metals monitoring by CEM issues and development for regulatory purposes. He has worked closely with Dr. Cooper and also may know of any other installations. Let's chat later today and see where to go from here. Jeff

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__________________________________________________ _ Jeff Ryan U.S. Environmental Protection Agency Office of Research and Development National Risk Management Research Laboratory Air Pollution Prevention and Control Division Air Pollution Technology Branch 109 T.W. Alexander Drive Mail Drop E305-01 Research Triangle Park, NC 27711 (919) 541-1437 (919) 541-0554 FAX" A nd all this science, I don't understand." "It's just my job 5 days a week" Elton John - Rocket Man

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__________________________________________________ _ David Ogulei 09/17/2012 05:28:19 PM Jeff, We are in the process of revising a title V p...
From: David Ogulei/R5/USEPA/US To: Jeff Ryan/RTP/USEPA/US@EPA Cc: Charles Hall/R5/USEPA/US@EPA Date: 09/17/2012 05:28 PM Subject: Multi-metal CEMS Jeff, We are in the process of revising a title V permit for a hazardous waste combustor (HWC) located in East St. Louis, MO (Veolia facility). We are currently exploring the option of requiring a multi-metal CEMS for monitoring heavy metal emissions for comparison to the HWC MACT standards. I am looking for technical analysis documents prepared or relied upon by EPA that discuss whether or not all of the previously known issues with multi-metal CEMS (and Hg CEMS) have been resolved. I've found some of your presentations on the Hg CEMS but I am more interested in the multi-metal CEMS. Do you have a good reference I can use for the multi-metal CEMS? Other than Eli Lilly, do you know of other facilities that are currently operating a multi-metal CEMS? Do we know of any outstanding issues that could hinder full deployment of a multi-metal CEMS in a HWC facility? Any issues reported by the facilities that are currently operating these systems? I also left you a voice message.
Thanks! -David
David Ogulei, Ph.D., P.E. U.S. Environmental Protection Agency Region 5 | Air & Radiation Division | A-18J 77 West Jackson Blvd. | Chicago, Illinois 60604 Phone: (312) 353-0987 | Fax: (312) 692-2080 Ogulei.David@epa.gov