9403 SW Nimbus Ave

Beaverton, Oregon 97008 www.cooperenvironmental.com Phone 503

- 670

- 8127 Fax 503

- 624

- 2120 

### Cooper Environmental Services, LLC Response to Comments from :

Veolia ES Technical Solutions, LLC

Test America and Focus Environmental, Inc
Coalition for Responsible Waste Incineration

Robert Baxter, B3 Systems


### Regarding:

R e v i s e d Comments Received In Docket ID: EPA

- R05

- OAR

- 2014

- 0280

Agency: Environmental Protection Agency

Air Pollution Control Title V Permit #V

- IL

- 1716300103

- 2014

- 10 (DRAFT)

For Veolia ES Technical Solutions, LLC

Prepared by Andr ea Geiger, Krag Petterson, and John Coope r

N o t e : T h i s d o c u m e n t h a s b e e n r e v i s e d f r o m t h e v e r

s i o n p o s t e d o n F e b r u a r y 1 8

, 2 0 1 5 o n t h e E P A D o c k e t I D E P A

- R 0 5

- O A R

- 2 0 1 4

- 0 2 8 0

- 0 1 1 3

. Cooper Environmental Services, LLC (CES) has reviewed the comments provided by Veolia and others commenting on Veolia ES Technical Solutions ’ (Veolia) Title V permit regarding the use of multi

- metal continuous emission monitoring system ( CEMS ) technology at the Veolia hazardous waste incinerator (HWI)

. CES is compelled to provide the US E nvironmental P rotection A gency (EPA) , for the purposes of placing in the public record, additional responses to va rious comments with the intent of:

 Clarifying technical aspects of the Xact multi

- metal CEMS functioning and performance,

 Dispelling some inaccuracies and misperceptions that are frequently reported in commentary from Veolia and their supporting organizati ons, and

 Supporting the technical and scientific integrity of CES in the development and design of our multi

- metals monitoring instrumentation

. It is important to state here, for the record, that CES was not involved in nor attempted to influence the development of any requirements in the past or present Title V permit for Veolia. Veolia’s comment (VES019536, Page 38) that EPA has “demonstrated bias by its collusion with Cooper,” is false and misleading. We would like to make it clear that no “col lusion” has occurred between the USEPA and CES with regard to the Xact multi

metal CEMS. We have provided answers to technical and costing questions posed by the USEPA, which is fully in line with any instrumentation company’s efforts in describing and det ailing the specifications and functionality of their instrument. It is natural that the company who invented and developed a technology would be the primary source ofMarch 27, 2015 Page 2 of 14

information with regard to that technology and, by no means, places either the
company or the regulatory body into a position of faltering morality.

CES had no involvement in the development of th e current draft Title V permit or the draft permit reopening in 2013. In fact, w e were not aware of the multi

- metal CEMS requirement before the perm it’s release for public comment. CES has dedicated considerable time and resources towards developing a robust technology for measuring multi

- metals in various conditions

. Our focus has always been, and will always be, placed on the development of new tec hnologies for measuring multi

- metals with the intent of protecting human health and the environment. We have not participated in any activities that could be considered unlawful or conspiratorial with the sole objective of monetary gain.



## Particulate Matter Transport Issues

From our review of comments submitted by Veolia, Test America / Focus Environmental

, Robert Baxter, Michael Fuchs and others, there are several topics frequently mentioned. A majority of the comments discuss the problems associated with par ticulate matter (PM) transport. This is an extremely complex topic, and we would like to include ou r input on the available research and our knowledge of the Xact’s performance with regard to the following topics:

1. Traverse versus single point sampling

Several commenters have suggested that single point sampling is not able to collect a representative sample

, because:

a. Variations in particle density can affect accuracy of single point sampling systems

. b. Transporting particulate is di fferent from transporti ng a gas; PM has stratification issues, and the Xact has no way of compensating for PM stratification.

c. The Xact CEMS cannot provide results consistent with actual stack gases, due to stratification

. To respond to the comment regarding both traverse versus single point sampling and PM stratification, we refer the EPA to prior work conducted using R&P Tapered Element Oscillating Microbalance (TEOMTM) monitors to evaluate PM stratification a t various points in a Coal

- Fired Power Plant ( CFPP ) emission stream. T his series of particulate matter measurement studies using paired TEOMs prepared by Edward Burgher and Gilles Gonnet i n a white paper, detail the lack PM stratification in measured stack emissions (accessed through Environmental Technology Online)

. The goa ls of the studies were to demonstrate and validate the capabilities of the TEOM monitor. The first part of the study details the validation of the TEOM monitors through comparison withMarch 27, 2015 Page 3 of 14

reference methods. The second part of the study evaluated the precision of side

- by

side monitors, while also evaluating the stratification of particulate matter within a stack (Burgher and Gonnet, 2004) . Two identically configured TEOM systems were insta lled in adjacent sampling ports; b oth single

- point and traverse measurements were collected

. In the single point sampling test, the sampling probes were inserted so that each probe nozzle was located at the centermost point of the stack, while the traverse test installed and configured the TEOMs to measure PM concentra tions at three discreet locations along the sample traverse line. Results of the testing conducted in the coal

- fired power plant emission source demonstrated excellent agreement between the co

- located TEOM monitors (< 8% difference), while also showing the sampling locations to be essentially non

- stratified with respect to particulate matter

.
T he full report is provided as A ttachment 1 to our comments , with selected tables and graphs provided below

. The results of the side

- by

- side TEOM monitoring are depict ed in Table 6 and Figures 1 and 2 of the article. To demonstrate the precision of the method, Figures 1 and 2 were created using two

- minute rolling average mass concentrations for each system.March 27, 2015 Page 4 of 14March 27, 2015 Page 5 of 14

2. Commentary that p article size issues cause an inability of the Xact to collect a representative sample.

CES found conflicting theories from th e commenters with regard to measurement issues caused by particle size.

VES016998 Robert Baxter comments:

“

... the Xact is unable to obtain a representative sample and will underestimate the larger particles, since those (by being trapped on the transport wall and not in the center of the stack) will no t be sampled, and enhance the concentrations of smaller particles.” Mr. Baxter also claims that the (former) Quantitative Aerosol Generator ( QAG ) 1 “ produces particles approximately 1 micron in size or less, which is not representative of Veolia’s emissions ’ particle size distribution (PSD)

. ” The reasoning Bob Baxter uses for claiming that the QAG does not appropriately estimate the size fraction present in Veolia’s stack gas is primarily based on stack velocities and the ability of the velocities present i n Veolia’s stack emissions to transport large particles up to 150 microns (as opposed to the ~1 micron average particle size produced by an old er QAG model) . Mr. Baxter, however, provides no evidence of the actual particle sizes present in Veolia’s post

- tr eatment emissions. Veolia’s process conditions may well produce larger particles, but those larger particles will be eliminated through use of the multiple pollution control systems in place. Multiple sources are available stating the 95%

- 99% collection efficiencies for baghouse control treatment (Somani, 1998; Honghong Yi, 2006) and that the particulate sizes in the post

- treatment emission stream is made up of small particles (< 1 μm ) (Park et al, 2012; Yi et al., 2006)

. In addition, prior studies have shown that metals showed “proportionally higher concentrations in the submicrometer particles compared to total mass.” (A.D. Shendrikar, 1983) While large particles, were they present in Veolia’ s waste stream, could be carried by the velocities found in Veolia’s emissions, it is highly unlikely that, following both spray

- drier absorber and baghouse treatments, particles over 1 micron would be found. As Mr. Baxter references in his commentary, PM particles do “act like a gas” for particles <1 μm ) (Mueller Environmental Designs, Inc, 2015) ; therefore, the argument that the Xact would not be capable of capturing a representative sample based on underestimating larger part icles does not apply.
From a physical perspective the majority of toxic metals in flue gas of HWI’s exist as fine particles (Donnelly, 1991) . Regardless , s i mply because the stack velocities can support up to 150 micron particl es does not mean that particles of that size will be present in stack emissions following pollution control treatments. A 2012 study published in the Journal of Aerosol and Air Quality Research investigated the filtration and cleaning characteristics of a baghouse filtration system (Park et al., 2012). The purpose of the

1 Note: CES has performed significant development of the QAG in recent years. The QAG now has the capability of modulating particle size and particle size distributions, and is being developed to replace PS11 at coal

- fired power plants.March 27, 2015 Page 6 of 14

study was to identify the capture efficiency for fine particles before and after baghouse cleaning procedures; they focused on evaluating collection efficiency for PM size fractions ranging from 0.45 to 2.5 microns. The researchers found that as particle size decreased, the collection efficiency decreased due to lower impaction effect during filtration with a fresh filter; however, there was no difference found in the collection efficiency f or particles over 0.725 microns during any phase of baghouse filter cleaning processes. In other words, Mr. Baxter’s concern that the Xact is not verified to produce results relatable to Veolia’s waste stream and particle size is unfounded. Even if particl e sizes produced from the QAG and transported to the Xact are 1 micron or less, that particle size fraction is accurately representative of the fine particles remaining following baghouse treatment.
In statements conflicting with those of Bob Baxter concer ning the particle size distribution likely to be present in Veolia’s stack Test America and Focus Environmental state clearly that the particulate emissions from a typical hazardous waste incinerator equipped with emissions controls are >99 percent less th an one micron in aero dynamic particle size (page 8 of Test America’s commentary ). Oddly, Test America uses this >99% less than 1 micron value to claim that the reason the Xact performed better on previous the Coal

- Fired Power Plant testing is because the particle sizes at a CFPP are larger, so in this case, the better performance of the Xact is due to larger particle sizes, which is in direct opposition to the reasoning made by Mr. Baxter. The Xact is able to sample and analyze a wide range of particle sizes, and the Xact analytical results for a representative sample are not dependent on particle size.

3. Concern over p articulate matter buildup on transport walls
Veolia’s comments include a series of figures (Figures 1.1 through 1.4 starting on page VES 019552) indicating the possibility of particles accumulating with a large chunk of particulate breaking off and depositing on the Xact’s filter tape. There are several reasons why this statement is neither accu rate nor likely . Firstly, t he Xact samples a subsample from the full emission stream and then collects another smaller subsample of that sample (see schematic in Figure 3) . The large chuck of built

- up PM on the transport wall would have to be extremely wel l distributed across the entire transport line to have the possibility of falsely impacting the Xact’s filter and detector. Secondly, Veolia
argu e s that particulate would adhere to the transport wall as the gas cools , which would lead to greater PM build u p on the transport walls . CES uses a heated transport line, so the argument that cooling gas emissions would deposit particulate on transport walls is simply not an issue. The temperature of the transport line is approximately 190°C, which is quite close t o the maximum temperature at Veolia prior to pollution controls of 204

- 216°C ( taken from Veolia’s Draft Title V CAA Permit, Operating Parameter Limits table, page 15). The temperature may cool after pollution control treatment, but it will not coo l (or onl y cool negligibly) in the Xact’s transport system , see representative schematic in Figure 3 below

.March 27, 2015 Page 7 of 14

Figure 3

– Schematic of Xact 640 Transport and Set Up

The sampling module and transport line of the Xact operate under high temperatures to prevent condensation of stack gas. Both the main line and the subsample line are continuously heated. The Xact 640 requires external heater controls for ensuring that the sample transport line is properly heated. The sample line heater controller must be s et to set to 19 0° C which allows for the transport of oxidized mercury species

, as well as preventing the condensation of water a nd acid vapors, as well as reduc ing the likelihood of particulate condensation on the transport line walls. In addition, the Xact samples a small subsample from the central flow through the transport line, so the large particle s that might break or flake off from the transport line ’s wall, unlikely as that may 190°CMarch 27, 2015 Page 8 of 14

be, would be extremely unlikely to have an impact on the concentration re ading of the Xact.

4. Commentary that t he validation of the Xact with the QAG fails to mimic actual stack conditions because the emission aerosols are not physically or chemically comparable to the forms used in the QAG aerosol

. Page 2 of Test America & Focus Environmental Inc comments (page 2 of 19):

“

... the Xact® CEMS Method 301 validation using the QAG fails to mimic the actual conditions in a hazardous waste incinerator stack gas. The specific materials used as standards are inappropriate chemically be cause they are not comparable to the actual chemistry and physical state of the compounds required to be measured in the stack gas.
Cooper Environmental Services chose soluble metal nitrates [such as chromium nitrate, Cr(NO 3 ) 3

] to prepare the QAG aerosol s olutions. Such easily dissolved metal compounds generate a matrix that lends itself favorably to the generation of the QAG aerosol. However, the aerosol generated using these easily dissolved metal nitrate salts in no way chemically compares to the hard

- fi red, resilient metal oxides compounds [such as chromium oxide, Cr 2 O 3 ] that normally exit combustion systems. Combustion temperatures and oxidative conditions produce metal emissions, typically oxides, which are very stable and generally insoluble in water without the aid of harsh chemical digestion. These tenacious chemical properties pose a formidable challenge to a QAG standard design which should use chemicals that are the same as the actual exhaust gas matrix chemical species.

To prove the Xact CEMS cap tures a representative sample and provides an accurate analytical result, the QAG generated matrix and the chemical species that are sampled should be compositionally the same as an actual stack gas. It is irrelevant that the X

- ray fluorescence (XRF) techn ology alone can purportedly accurately detect metal concentrations on the proprietary reactive filter tape regardless of the matrix. The issue is not the analysis technology, but the sample collection.”

As the authors acknowledge

, t he total metals analysis used in the XRF analysis of the Xact is independent of oxidation state

, chemical matrix, refractory oxides, or difficult to dissolve metal compounds. The form of metal compounds would be significant for an analysis method such as i nductively coupled plasma

– mass spectrometry (ICP

- MS), but it does not apply to total metals analysis of particulates and vapor

- phase metals captured on the treated filter media of the Xact

, because the metals are n either

remov ed n or dissolv ed and XRF use s inner shell electron transition lines to quantify the amount of metal, which is entirely separate from chemical compound form.March 27, 2015 Page 9 of 14

The question then is whether the aerosol created by the nebulization of metals dissolved in nitric acid solution behave differ ently

, either chemically or physically

, from the metal oxides likely to be produced from the incineration process. Table 1 shows the typical melting points of various metal oxide species along with the melting points of the corresponding nitrate salts. T he melting point data for the oxide species reinforces the fact that these elements are present principally in the particulate phase at the temperatures found in Veolia’s stack emissions. Although c hromium and arsenic start out as nitrate salts , they will decompose to form the oxides at the temperatures found in the QAG and the Xact transport line (Malecki et al, 2003) . This means that these elements, when spiked are both chemically and physically, identical to the species being emitted. In addition

, it is clear from the table that both the lead and cadmium nitrate species will also be in the particulate phase at the te mperatures found in the stack. This means that these elements will transport in a manner similar to that of the stack emissions for thes e metals. Finally

, since all of the material coming in contact with the stack gas in the Xact’s transport line and probe is either Teflon coated metal, Teflon tubing

, or inert metal tubing (Titanium and Hastalloy)

, it is simply not reasonable that the lea d and cadmium nitrate or oxide species will react with any of these components.
After the sample has been transported to the instrument

, a small sub

- sample is withdrawn through a reactive filter tape ; h owever, al l of the particulate phase species

, whether emitted by the QAG or sampled from stack effluent

, are captured on the filter tape via a physical

– rather than a chemical

- filtration process. The characteristics of the filter media are such that greater than 99.9% of all particulates 0.3 μ m or larger are caught on the tape this means that all of the lead, arsenic, cadmium and chromium

, whether generated by the QAG or coming from the stack

, are captured on the filter tape via this filtration process.
Mercury is the only species from the table t hat is present to any degree in the vapor phase. Mercuric nitrate melts at 79C and is completely in the vapor phase in the QAG aerosol. Mercuric oxide, however, if emitted by the species is not in the vapor phase. If mercury is present in the particulat e phase in Veolia’s effluent it will transport similarly to the other vapor phase species. Additionally if it is in the particulate phase it will also be captured by the same physical filtration process as the other metals. If mercury is present in the v apor phase (and the use of activated carbon at Veolia to control mercury suggests that it is) then the vapor phase mercury generated from the QAG tests both the transport and capture of vapor phase mercury.March 27, 2015 Page 10 of 14



### Table 1. Melting Points of Select Hazardous M etal Oxides and Nitrates

Metal Melting Point (°C)*

Nitrate Oxide

Cd 360 900

- 1000

Cr +3 Thermally decomposes to oxide 2432

Pb 470 489

As Decomposes to oxide 274

- 315 Hg 79 500 Appx Temp of Xact 640 Transport Line (°C) 190 Maximum Temp of HWI Gas at Control Device Inlet (°C)^ 204

- 216

Footnotes: *All information sourced from the CRC Handbook of Chemistry and Physics, 95 ed (accessed online 01/23/2015), with the exception of Cadmium Oxide, which was sourced from International Programme

on Chemical Safety and the European Commission (accessed online 01/23/2015) ^ Temperature taken from Draft Veolia Permit No. V

- IL

- 1716300103

- 2014

- 10, Operating Parameter Limits (420°F for Incinerators 2 and 3 and 399°F for Incinerator 4)

In addition to the melting point data shown in table 1 CES has per formed additional testing to evaluate trapping efficiency using the X

- Ray Filter Method (XFM). The filters set up within the XFM include a particulate filter followed by a chemically treated filter for capturing vapor

- phase metals (see Figure 4

, below) . The results of the XFM testing demonstrated that 98 % of the total sample was present in the particulate form

, demonstrating that the QAG is producing a particulate that can effectively mimic t he particulate phase present for most metals (other than vapor phase mercury)

. The full report i s included in Attachment 2.March 27, 2015 Page 11 of 14

5. Budgetary concerns . Veolia states a number of times that CES keeps “its monetary options flexible by including variable cost factors that could be used to increase the price” (VES019545, p a g e 47).
CES’ pricing is the same for Veolia as for any other customer. Pricing for t he variable items

, such as transport length to accommodate the location of the CEMS in relation to the sample port or the amount of filter tape needed for varying sampl ing intervals

, depend greatly on an individual facility ’s needs . This type of variability (particularly the variability due to samp le line length ) is not unique to CES’ pricing, and it exists for any instrumentation company installing a CEMS at a new facility . It is also important to state that CES has offered on at least two occasions ( phone call on 12/11/2014 and email on 1/7/2015 ) to travel to Veolia’s facility so that we can provide a firm quote, yet th e s e offer s were not accepted. Until an evaluation can be performed to prepare an informed quote, any commentary on this topic is purely speculative, and should be considered as such.

6. Error in operational description, Test America/Focus Environmental comments, page 3:
“The XACT® CEMS operates on a repeating 15

- minute cycle time. For approximately 12 minutes of each cycle, a sample of stack gas is extracted via a heated sampling probe a nd drawn through a filter element. The filter element is a proprietary, chemically infused material designed to capture metals. The filter element is mounted on a reel similar to tape. After sampling, the filter media is advanced on the reel to move the sa mple to the XRF analyzer and expose fresh filter media for the next sampling cycle. The filter media advancement and XRF analysis takes approximately 3 minutes.”
CES Response: Although some of the factors described in Test America’s description of the Xact technology are partially correct, there are several errors. Firstly, it takes approximately between 20 to 45 seconds for the tape to advance from the sampling to analysis area (not three minutes)

. The only time that the Xact pauses in its sampling of stac k gas is during this advancement period, so a 12 minute sample period with three minute advancement time is incorrect. The XRF analysis occurs at the same time and for the same duration as the subsequent sample is being collected, it is not performed durin g the sample advancement period, as indicat ed in the Test America

- Focus Environmental description

.
7. Commentary regarding the Xact’s ability to collect v apor

- phase (elemental)

m ercury (Hg°)

Test America/Focus Environmental questions the Xact’s ability to capture vapor phase mercury, and suggests that the Xact’s better performance (as compared to Method 29) is related to the particulate nature of emissions from CFPP . It is well known that the

ma jority of mercury emissions is suing from CFPPs is primarily in the vapor phase. HgMarch 27, 2015 Page 12 of 14

deposition currently estimated using contemporary in

- stack speciation estimates show that Hg 0 i s the dominant form (84

- 88 %) (Landis et al. 2014 ; Edgerton et al., 2002 ; Lohman et al, 2006; EPRI, 2006; Kos et al, 2013; Yee

- Lin et al, 2012; Lehigh University ERC, 2007 )

Test America/Focus Environmental also suggest that CFPPs emissions would contain significant amounts of carbon which could behave similarly to activated carbon. ( Activated carbon is used r outinely for controlling mercury emissions. ) It seems unclear to CES why a CFPP would need to use activated carbon injection pollution control systems if there is already carbon entrained in their stack emissions that behaves like activated carbon and trap s vapor

- phase mercury

. They claim that it is the affinity for mercury to adhere to carbon par t icles that allows the Hg 0 to be easily captured by the Xact CEMS ’ reactive filter media (as a particulate). Test America/Focus Environmental claim that it is this “phenomenon” that explains the Xact’s better performance for mercury capture (when compared to Method 29) for coal

- fired units.

It should be noted that t here are no references included with the conjectures presented in Test America /Focus Environmental ’s commentary, but in our research into mercury emissions and stack testing, CFPP have, if anything, a higher percentage of
vapor

- phase mercury in their emissions than HWI’s. They would certainly have a higher level of consistent vapor phase mercury, since t hey do not burn the wide variety of waste sources incinerated at Veolia. Multiple reports state that particulate mercury in CFPP emissions is less than 1% of the total emissions (Lohman et al., 2006)

. In an extensive search of stack

- based mercury testing, CES found no published works regarding the presence of entrained carbon in CFPP emissions and/or that carbon’s ability to absorb Hg°.
CES has performed extensive testing on the ability of the Xact to capture vapor

- phase
mercury. In all tests, elemental mer cury trapping efficiency exceeded 99%

. We are attaching a collection of additional data and reports in support of the Xact’s performance with regard to mercury and other candidate method comparisons. This information , and others with respect to the Xact’s ability to capture vapor

- phase
mercury, is provided as Attachment 2. In addition, CES refers the reader to the multiple patents granted to CES for our methods developed to capture vapor

- phase mercury (see Attachment 3)

. In closing, CES hopes that this com mentary provides additional supporting documentation with regard to the contrary claims of Veolia and other commenters. Overall, CES requests that EPA focus on the science, technology, and factual history of both Veolia and the Xact multi

- metal CEMS. We fe el it is essential to separate an industry’s negative response to a requirement for installing a specific monitoring instrument from the integrity of the science and technology in developing that instrument.March 27, 2015 Page 13 of 14

Note: Additional commentary and supporting docum entation provided with CES’ submittal to Veolia’s Draft Permit # V

- IL

- 1716300103

- 2014

- 10 on December 19, 2014. (USEPA Docket ID EPA

- R05

- OAR

- 2014

- 0280 )



# Works Cited

A.D. Shendrikar, D. E. (1983). Size

- dependent penetration of trace elements thr ough a utility baghouse. Atmospheric Environment , 1411

- 1421.
Anil Somani, S. A. (1998). Airborne Particulate Matter: Pollution Prevention and Control. In W. B. Group, Pollution Prevention and A b atement Handbook (pp. 235

- 239). Washington D.C.: The International Bank for Reconstruction and Development.

Baxter, Robert, 2014. Evaluation of the Xact Multi

- Metal CEMS. December 11, 2014.
Byung Hyun Park, S. B.

- H. (2012). Filtration Characteristics of Fine Particulate Matters in a PTFE/Glass. Aerosol and Air Quality Research, , 1030

- 1036.
Donnelly, J. (1991). Metals Emissions Control Technologies for Waste Incineration. Argonne National Library.
Edgerton E, Hartsell BE, Jansen JJ (2012) . Paper presented at Air Quality

- III: Mercury, Trace Elements, and Particulate Matter; 2002 Sep; Arlington, VA.
Electric Power Research Institute (US). Mercury Chemistry in Power Plant Plumes. Environmental Research Program final report. Palo Alto, CA: 2006.

Fuchs, Michael. 2014. Comments by Michael Fuchs on behalf of Veolia ES Technical
Solutions. L.L.C. on the Draft Title V Permit and the Statement of Basis Dated October
2014
Geiger, Andrea, Krag Petterson, and John Cooper, 2014. Cooper Environmental Services, LLC Comments t o United Stat es Environmental Protection Agency, Region 5 Air Pollution Control Title V Permit #V

- IL

- 1716300103

- 2014

- 10 (DRAFT) . December 19

, 2014

.
Kos, G, Ryzhkov, A, Dastoor, A, Narayan, J, Steffen, A, Ariya, PA, and Zhang, L: Evaluation of discrepancy between measur ed and modelled oxidized mercury species, Atmos. Chem. Phys., 13, 4839

- 4863.
Landis MS, Ryan JV, ter Schure, AF, Laudal D. 2014 Nov. The Behavior of Mercury
Emission from a Commercial Coal

- Fired Power Plant: The Relationship between Stack Speciation and Ne ar

- Field Plume Measurements. Environmental Science and Technology 48 (22): 186

- 191.March 27, 2015 Page 14 of 14

Lehigh University Energy Research Center (US). Evaluation and Comparison of U.S. and EU Reference Methods for Measurement of Mercury, Heavy Metals, PM 2.5 and PM 10 Emissions from Fossil

- Fired Power Plants. Final report. Bethlehem, PA: 2007 Feb.
Lohman K, Seigneur C, Edgerton E, Jansen J. 2006 Jun. Modeling Mercury in Power Plant Plumes. Environmental Science and Technology 40(12): 3848

- 3854.
Malecki, A, B Malecka, R Gajerski, and S Labus, 2003. Thermal Decomposition of Chromium(III) Nitrate(V) Nanohydrate Different Chromium Oxides Formation. Journal of Thermal Analysis and Calorimetry 72: 135

- 144.
Mueller Environmental Designs, Inc. (2015, February 4). Fundamentals of Gas
Soli ds/Liquids Separation. Retrieved from www.muellerenvironmental.com.
Test America (William C. Anderson) and Focus Environmental, Inc (Chris McBride), 2014. Viability of the Xact Multi

- metal CEMS as a Tractable Instrument for the collection of metals data related to HWC MACT compliance standards. December 9, 2014.

Veolia, 2014. Comments of Veolia ES Technical Solution s, LLC to Draft Air Pollution
Co ntrol Title V Permit to Operate , Permit No. V

- IL

- 1716300103

- 2014

- 10. Decembe r 17,
2014.
Warchol, Dennis, 2014. Comments and Affidavit of Dennis J. Warchol in Support of Veolia ES Technical Solutions, LLC. to Draft Air Pollution Control Title V Permit to Operate,
Permit No. V

- IL

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- 2014

- 10. December 12, 2014.
Yi, Honghong, Jiming Hao, Lei Duan, Xinghua Li, and Xingming Guo, 2006.
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