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:

Revised 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 Andrea Geiger, Krag Petterson, and John Cooper

Note: This document has been revised from the version posted on February 18, 2015 on

the EPA Docket ID EPA-R05-OAR-2014-0280-0113.

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 Environmental Protection Agency (EPA), for the purposes of placing in 

the public record, additional responses to various 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 organizations, 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 “collusion” has occurred between the USEPA and CES with regard to the Xact multimetal 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 detailing the specifications and functionality of their instrument. It is natural that the 

company who invented and developed a technology would be the primary source of 
March 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 the current draft Title V permit or the 

draft permit reopening in 2013. In fact, we were not aware of the multi-metal CEMS 

requirement before the permit’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 technologies 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 particulate matter 

(PM) transport. This is an extremely complex topic, and we would like to include our

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 different from transporting 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 at various 

points in a Coal-Fired Power Plant (CFPP) emission stream. This series of particulate 

matter measurement studies using paired TEOMs prepared by Edward Burgher and 

Gilles Gonnet in a white paper, detail the lack PM stratification in measured stack 

emissions (accessed through Environmental Technology Online). The goals 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 with 
March 27, 2015 Page 3 of 14

reference methods. The second part of the study evaluated the precision of side-byside monitors, while also evaluating the stratification of particulate matter within a stack

(Burgher and Gonnet, 2004). Two identically configured TEOM systems were installed in 

adjacent sampling ports; both 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 concentrations 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. 

The full report is provided as Attachment 1 to our comments, with selected tables and 

graphs provided below. The results of the side-by-side TEOM monitoring are depicted 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 14
March 27, 2015 Page 5 of 14

2. Commentary that particle size issues cause an inability of the Xact to collect a 

representative sample.

CES found conflicting theories from the 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 not 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 in Veolia’s stack emissions to transport large particles up to 150 

microns (as opposed to the ~1 micron average particle size produced by an older QAG 

model). Mr. Baxter, however, provides no evidence of the actual particle sizes present

in Veolia’s post-treatment 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 

particles 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, simply because the stack velocities can support 

up to 150 micron particles 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 for 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 particle 

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 concerning 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 than one micron in aerodynamic 

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 particulate 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 accurate nor likely. Firstly, the 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 well distributed across the entire transport line to have 

the possibility of falsely impacting the Xact’s filter and detector. Secondly, Veolia 

argues that particulate would adhere to the transport wall as the gas cools, which 

would lead to greater PM build up 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 to 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 cool (or only 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 set to

set to190°C which allows for the transport of oxidized mercury species, as well as 

preventing the condensation of water and acid vapors, as well as reducing 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 

particles that might break or flake off from the transport line’s wall, unlikely as that may 

Roof

Exhaust return to stack

Xact

Stack Heated sample line 100-600 lpm

1 lpm XRF analysis area Filter tape

Probe 190°C
March 27, 2015 Page 8 of 14

be, would be extremely unlikely to have an impact on the concentration reading of the 

Xact. 

4. Commentary that the 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 because 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(NO3)3] to prepare the QAG aerosol solutions. 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-fired, resilient 

metal oxides compounds [such as chromium oxide, Cr2O3] 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 captures 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) technology 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, the 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 inductively 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 neither

removed nor dissolved and XRF uses 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 differently, 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. The 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 chromium 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 temperatures found in the 

stack. This means that these elements will transport in a manner similar to that of the 

stack emissions for these 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 

lead 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; however, all 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 μm 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 that 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 particulate 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 vapor 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 Metal 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 performed 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 the 

particulate phase present for most metals 

(other than vapor phase mercury). The full 

report is 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, page 47).

CES’ pricing is the same for Veolia as for any other customer. Pricing for the 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 sampling intervals, 

depend greatly on an individual facility’s needs. This type of variability (particularly the 

variability due to sample 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 these

offers 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 and 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 sample 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 

stack 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 

during the sample advancement period, as indicated in the Test America-Focus 

Environmental description. 

7. Commentary regarding the Xact’s ability to collect vapor-phase (elemental)

mercury (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 

majority of mercury emissions issuing from CFPPs is primarily in the vapor phase. Hg 
March 27, 2015 Page 12 of 14

deposition currently estimated using contemporary in-stack speciation estimates show

that Hg0is 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 routinely 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 traps vapor-phase mercury. They claim that it is the affinity for 

mercury to adhere to carbon particles that allows the Hg0to 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 there 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 they 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 mercury 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 commentary 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 feel 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 documentation 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

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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 Abatement 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 to United States 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 measured 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 Near-Field Plume Measurements. Environmental Science and 

Technology 48 (22): 186-191.
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Lehigh University Energy Research Center (US). Evaluation and Comparison of U.S. and 

EU Reference Methods for Measurement of Mercury, Heavy Metals, PM2.5 and PM10

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.

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Chromium(III) Nitrate(V) Nanohydrate Different Chromium Oxides Formation. Journal of 

Thermal Analysis and Calorimetry 72: 135-144.

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Solids/Liquids Separation. Retrieved from www.muellerenvironmental.com.

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Control Title V Permit to Operate, Permit No. V-IL-1716300103-2014-10. December 17, 

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Permit No. V-IL-1716300103-2014-10. December 12, 2014.

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