Discussion with Evonik DeGussa Discussion with Evonik DeGussa-MM CEMS MM CEMS 

Sarah Marshall Sarah Marshall to:

Jeff Ryan, Charles Hall, Dan Bivins, 

David Ogulei, Kim Garnett, Shannon 

Downey

10/04/2012 08:58 AM

Cc: Sabrina Argentieri

History: This message has been replied to and forwarded .

I spoke with Theresa Rexall (sp?) at Evonik about the MM CEMS. She is happy to set up a call with 

the group to discuss what happened. She was not involved with MM CEMS at the time of operation 

but she will get the appropriate people who operated it to describe to us why they have ceased 

operating the CEMS. 

Generally, she said that there was a hard drive failure in 2009 which was repaired and then a 

software failure in 2011 that they were unable to repair which would have required them to replace 

the system. Evonik got a quote from Pall for a new unit ($250,000 for the unit and $20,000 for the 

tape) and did a cost benefit analysis. They decided to not replace the unit since their waste is not 

variable and they did not see many spikes in metals and mercury while operating it . Evonik also 

had some problems with the sampling train. Those could be repaired but it added to the cost to get 

the MM CEMS running again. 

As for their waste analysis, they were not doing anything different while operating the MM CEMS so 

there was not a cost savings associated with waste analysis while operating the MM CEMS.

We can set up a call in the next few weeks. If you are interested, please let me know your 

availability over the next two weeks. 

Thanks!

Sarah Marshall

Environmental Engineer

Air Enforcement and Compliance Assurance Branch

U.S. Environmental Protection Agency, Region 5

312-886-6797

Jeff Ryan Good morning everyone. I just wanted to let... 10/02/2012 07:47:38 AM

From: Jeff Ryan/RTP/USEPA/US

To: Charles Hall/R5/USEPA/US@EPA, Dan Bivins/RTP/USEPA/US@EPA, David 

Ogulei/R5/USEPA/US@EPA, Kim Garnett/RTP/USEPA/US@EPA, Sarah 

Marshall/R5/USEPA/US@EPA, 

Cc: Richard H Lambert <lambert_richard_h@lilly.com>, Michael L Foster 

<foster_michael_l@lilly.com>

Date: 10/02/2012 07:47 AM

Subject: Conference call with Eli Lilly

Good morning everyone. I just wanted to let you know that I have had a chat with Rick and Mike 

prior to our call today and I wanted to pass along some additional info . Mainly, that this conference 

call today is focused on technical issues. Rick and Mike can speak to their experiences with the 

system while they were responsible for its operation. I now know that they are no longer responsible 

for the incinerator and that Evonic DeGussa now owns and operates the facility (since 2010). As a

result, our discussions are limited to the Eli Lilly operations.
Between Pall and Eli Lilly, several excellent papers and presentations have been provided . Initially, 

this is exactly what you all were looking for. I hope everyone has had a chance to go through them . 

In addition, I provided the links to the EPA documents that were produced specific to the alternative 

monitoring aspects.

I hope this helps.

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

____________________________________________________