Abstract

Mercury continuous emissions monitoring systems (CEMs) are being implemented in over 800 coal-fired power plant stacks throughput the U.S. Western Research Institute (WRI) is working closely with the Electric Power Research Institute (EPRI), the National Institute of Standards and Technology (NIST), and the Environmental Protection Agency (EPA) to facilitate the development of the experimental criteria for a NIST traceability protocol for dynamic elemental mercury vapor calibrators/generators. These devices are used to calibrate mercury CEMs at power plant sites. The Clean Air Mercury Rule (CAMR) which was published in the Federal Register on May 18, 2005 and vacated by a Federal appeals court in early 2008 required that calibration be performed with NIST-traceable standards. Despite the vacature, mercury emissions regulations in the future will require NIST traceable calibration standards, and EPA does not want to interrupt the effort towards developing NIST traceability protocols. The traceability procedures will be defined by EPA. An initial draft traceability protocol was issued by EPA in May 2007 for comment. In August 2007, EPA issued a conceptual interim traceability protocol for elemental mercury calibrators. The protocol is based on the actual analysis of the output of each calibration unit at several concentration levels ranging initially from about 2-40 {micro}g/m{sup 3} elemental mercury, and in the future down to 0.2 {micro}g/m{sup 3}, and this analysis will be directly traceable to analyses by NIST. The EPA traceability protocol document is divided into two separate sections. The first deals with the qualification of calibrator models by the vendors for use in mercury CEM calibration. The second describes the procedure that the vendors must use to certify the calibrators that meet the qualification specifications. The NIST traceable certification is performance based, traceable to analysis using isotope dilution inductively coupled plasma/mass spectrometry (ID/ICP/MS) performed by NIST in Gaithersburg, MD. The outputs of mercury calibrators are compared to one another using a nesting procedure which allows direct comparison of one calibrator with another at specific concentrations and eliminates analyzer variability effects. The qualification portion of the EPA interim traceability protocol requires the vendors to define calibrator performance as affected by variables such as pressure, temperature, line voltage, and shipping. In 2007 WRI developed and conducted a series of simplified qualification experiments to determine actual calibrator performance related to the variables defined in the qualification portion of the interim protocol.

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