1034 OSPREY PT

, LITTLETON NC 27617

- 7503 • PHONE ( 252) 586.7938 

# EMISSION MONITORING INC
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 c lear the misleading and erroneous statements made by CES.1034 OSPREY PT

, LITTLETON NC 27617

- 7503 • PHONE ( 252) 586.7938 

# EMISSION MONITORING INC
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) prese ntation and an incorrect statement in your comments. This has caus ed confusion on the part of others , m ay 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 as sociated 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 E n gineering Fo undation 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 serie s 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 n o t provide written papers, there are no written proceedings, and the conference participants are not allow ed to publish any of the data or information, other than their own, presented during the conference

. ” 2. I received a n 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 supporting1034 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 gene rally never given out. ” Dr. Kinner offe red 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 oth er 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 U sing an In

- Stack Inertial Microbalance ” Appendix X1

– “ G uidelines 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 sit e

- specific basis to determine if PM concentratio n stratification is significant across a stack or duct. However, I do not see how that would help address the sample line loss issues, represent a tiveness of the X AC T subsample, or potential PM metals concentration variation across the stack or by particle size distribution.

Sincerely,

James W. Peeler, President