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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 respon se to your first question. We would be able to del iver a unit on site
within 4 to 5 months then we should allow 2 to 3 mo nths 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.c om] 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 date d June 21, 2013. My responses to each question are given in r ed. In addition I have attached several files in r esponse 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 CE MS. The Xact CEMS is available commercially from Cooper Environmental Services, LLC. (CES) Pall Corporatio n 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 64 5 (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 tes ting sponsored by various organizations including U .S. EPA, Electric Power Research Institute (EPRI) and Eli Li lly.

Xact 620/625 Korea – 6 units purchased by National Institute of Environmental Research2

China – 9 units purchased by various Environmental Monitoring Centers Canada – 8 units Ontario Ministry of Environment, E nvironment 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 m ulti-metals CEMS for measuring emissions from heter ogeneous
waste streams.

The Xact and the filter chemistry utilized by the X act 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 diffe rent fuel types including coal (sub-bit, lignite and bituminous), natural gas, and diesel fu el and testing has occurred at facilities with different pollution controls like ESP's, bagho uses, and wet scrubbers. The Xact has been tested on facilities with stack temperatures r anging 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 s pecies 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 compo nents 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 che mistry is refreshed with every sample eliminating the problems with the chemistry becomin g spent over time. Also the Xact employs sample dilution prior to the filter trapping allowi ng 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 a llows the Xact to be chal lenged by a known concentration of metals in the presence of potentia lly interfering components from the stack

gas.

I’ve attached two files with details on the range o f 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 Ru le.pdf – these give additional details on places the Xact has been tested.

3. Case studies documenting application and/or deploym ent of the Xact multi-metals CEMS.
Please see the files above. In addition I would ad d 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 gr ant. 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 o n an ambient unit but demonstrates the accuracy of the technology3



### 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 a nd documents our comparison with Method 30B for mercury.

4. List of locations/facilities where the Xact multi-m etals CEMS is currently deployed and operating for any reason. I’ve listed the facilities were the Xact CEMS was d eployed

1. Eli Lilly’s Tippecanoe Laboratories, Lafayette IN – Deployed and operated for 6 years. The facility i s under new ownership and the Xact is no longer opera ted.

2. U.S. Army – Tooele UT munitions test furnace – It o perated periodically at this facility as the U.S. A rmy tested procedures for burning different types of mu nitions.

3. U.S. Army – Tooele, UT production furnace. The Xac t was installed at this facility but was never operated because regulations were never required fo r it.

4. U.S. Army – Crane, IN production furnace. The Xact was installed at this facility but was never operat ed because regulations were never required for it.

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

Eli Lilly was only client that utilized the Xact CE MS for compliance purposes it handled the beryllium issue as follows (quoted from Lilly’s AMP)

**“Because the XACT is incapable of measuring berylli um (Be), Lilly has developed a default value for be**  **ryllium emissions.**  **Fortunately, beryllium is a scarce element that is not used in Lilly pharmaceutical manufacturing proc**  **esses. Lilly has examined all its manufacturing processes and associ**  **ated process construction materials (e.g. alloy ste els) and found no**  **indic ation that beryllium should be present. Therefore,**  **Lilly believes that a conservatively calculated def ault value for**  **beryllium is technically defensible.**
**Trace levels of beryllium are possible in raw mater ials 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-liqui d incinerator, and some low-levels of beryllium wer**  **e reported. For the purposes of calculating a conservative default emis**  **sion concentration, Lilly has assumed that all liqu id and solid wastes**  **fed to the solid-liquid incinerator contain Be at t he maximum levels detected: 1.0 ppm in the solid wa**  **ste and 0.01ppm in the liquid wastes. The default emission concentrati**  **on 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 de**  **sign SRE of 99% and a factor of 20 less than the SRE of 99.9% obtai**  **ned during the CPT of another Lilly incinerator wit h a virtually identical**  **scrubber system). The resulting value was just over 1 ug/dscm. To be more conservative, Lilly has chos**  **en 2 ug/dscm as a default value. Therefore, a value of 2 ug/dscm will**  **be added to the measured LVM emission before compa rison to the**  **emission standard limit. If the CPT data or any oth er evidence indicates the default value is not appr**  **opriate, it will be adjusted accordingly.”** 

6. Estimated timeline for deployment of the Xact multi -metals CEMS at an existing facility, i.e., from or der date to operation. What are the potential challenges?

We believe that a 9 month time line is sufficient a nd includes manufacturing, shipping installation an d RATA testing.

Krag Petterson
Vice President Cooper Environmental Services, LLC
10180 SW Nimbus Ave Ste. J6 Portland, OR 972234 503-670-8335