1034 OSPREY PT, LITTLETON NC 27617-7503 • PHONE (252) 586.7938

EMISSION MONITORINGINC 

EFFECTIVE SOLUTIONS AND ADVANCED TECHNOLOGIES

EMISSION MONITORING INCORPORATED (EMI)

RESPONSE TO COMMENTS FROM:

COOPER ENVIRONMENTAL SERVICES, LLC

On

Air Pollution Control Title V Permit #V-IL-1716300103-2014-10 (DRAFT) For

Veolia ES Technical Solutions, LLC

Docket EPA/RO5/OAR/2014-0280

Emission Monitoring Incorporated (EMI) is submitted the attached letter for submission 

to the Docket: EPA-RO5-OAR-2104-0280 regarding the Veolia EA Title V Permit Draft.

The attached letter to Cooper Environmental Services (CES) explains that their 

comments submitted to same Docket are misleading and erroneous. EMI requests that 

they remove references to our company name and research.

EMI realizes that the Docket has closed, and was indeed closed when CES submitted 

their comments in February of 2015.

Our late submission is due to the fact that the CES comments were only recently brought 

to our attention on March 25, 2015. 

EMI respectfully requests that this cover letter and attached letter be placed in the Docket 

to clear the misleading and erroneous statements made by CES.
1034 OSPREY PT, LITTLETON NC 27617-7503 • PHONE (252) 586.7938

EMISSION MONITORINGINC 

EFFECTIVE SOLUTIONS AND ADVANCED TECHNOLOGIES

March 26, 2015

Dr. John Cooper

Cooper Environmental Services, LLC

9403 SW Nimbus Ave 

Beaverton, Oregon 97008

Dear Dr. Cooper:

It has been brought to my attention that Cooper Environmental Services, LLC (CES) has 

submitted comments on “Air Pollution Control Title V Permit #V-IL-1716300103-2014-10 

(DRAFT) For Veolia ES Technical Solutions, LLC” which includes an incorrect citation to a

prior Emission Monitoring Inc. (EMI) presentation and an incorrect statement in your 

comments. This has caused confusion on the part of others, may lead to incorrect 

conclusions by others, and has necessitated that EMI take time to investigate and 

prepare this and other correspondence. We request that you resubmit your comments 

on this matter after deleting paragraph 3 (the reference and associated remarks) on 

page 3 and in the reference list on page 14.

EMI is troubled by these remarks and the manner in which this occurred for the 

following reasons:

1. The subject reference is in conflict with the long standing tradition of the former 

“United Engineering Foundation Conference on Source Testing” now the 

“Stationary Source Sampling and Analysis for Air Pollutants” (SSSAAP) 

Conference that that presentations are not cited or quoted in order to promote 

free communication and discussion. As a long time attendee of this conference 

series you will recall that we actually signed a card agreeing not to cite or quote 

presented information for the UEF Conferences. The 2011 SSSAAP program the 

statement; “Presenters do not provide written papers, there are no written 

proceedings, and the conference participants are not allowed to publish any of 

the data or information, other than their own, presented during the 

conference.”

2. I received an e-mail request from Andrea Gieger, CES on January 21, 2015 which 

indicated CES was familiar with prior work by EMI using the TEOM 7000 and 

included: “I wanted to find out if there are any specific publications, or any other 

documentation, on PM stratification, as it would be very helpful in supporting 
1034 OSPREY PT, LITTLETON NC 27617-7503 • PHONE (252) 586.7938

our perspective on the ability of continuously monitoring multi-metals with the 

Xact on HWI stacks.” I was not able to respond to this request.

3. The request was subsequently sent to Dr. Laura Kinner on January 28 who 

responded that the SSSAAP conference “has no papers by design” and “I am 

unsure if any papers were actually published that are in the public domain but 

will check.”

4. On February 5, Andrea Gieger sent another e-mail requesting an unspecified 

“SES” paper. Dr. Kinner responded that “Our data are confidential though and 

SES presentations are generally never given out.” Dr. Kinner offered to check 

with the client(s) about releasing data.

5. Andrea Gieger’s response included: “Ah, I see. That makes sense,” and “I really 

appreciate you checking on this. I definitely understand the sensitive nature of 

stack emissions testing.”

6. With no further communication between EMI and CES, CES included the 

incorrect reference to a presentation on other issues. The referenced document 

does not support the CES statement: “This study also compared PM 

measurements collected with traverse and single-point sampling methods and 

found that no stratification was present in the stack measured.”

7. Other parties have told us that the subject EMI reference in CES’s comments

appearing immediately above Table 6 derived from the paper prepared by 

Edward Burgher and Gilles Gonnet lead them to believe that this was EMI’s data. 

Dr. Kinner communications with Andrea Gieger clearly stated that this was not 

the case.

In summary, EMI has no publications or data in the public domain to provide for this 

matter as we have previously indicated. EMI has no interest in further participation in 

this exchange.

I can direct you to ASTM D6831-11 “Standard Test Method for Sampling and 

Determining Particulate Matter in Stack Gases Using an In-Stack Inertial Microbalance”

Appendix X1 – “Guidelines for Assessing Spatial Variation in Particulate Matter 

Concentration.” This is an empirical procedure using the Series 7000 TEOM (or similar 

device) which may be used on a site-specific basis to determine if PM concentration 

stratification is significant across a stack or duct. However, I do not see how that would 

help address the sample line loss issues, representativeness of the XACT subsample, or 

potential PM metals concentration variation across the stack or by particle size 

distribution.

Sincerely, 

James W. Peeler, President