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

____________________________________________________

 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

____________________________________________________

David Ogulei Let's see if Dr. Cooper knows of any additional d... 09/18/2012 02:33:16 PM

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 PM
Subject: 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 I'm going to meet with John and Doug tomorrow... 09/18/2012 12:25:46 PM

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

____________________________________________________

 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

____________________________________________________

Dan Bivins Jeff and David, I'm kinda like you Jeff, don't kno... 09/18/2012 12:43:49 PM

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.

Dan
Jeff Ryan Hi David Hopefully I can help you out. I am VER... 09/18/2012 08:41:05 AM

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

____________________________________________________

 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

____________________________________________________

David Ogulei Jeff, We are in the process of revising a title V p... 09/17/2012 05:28:19 PM

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