United States      Office of Air Quality      EPA-450/3-82-008
Environmental Protection  Planning and Standards     February 1982
Agency        Research Triangle Park NC 27711
Air
Revisions to Methods
101,101A, and 102
for Determination
of Mercury Emissions

Summary of Comments
and Responses

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                                  EPA-450/3-82-008
                  Revisions to
      Methods  101. 101A, and 102 for
    Determination of Mercury Emissions
(Proposed October 15, 1980,45 FR 68514)

   Summary of Comments and Responses
              Emission Standards and Engineering Division
              U.S. ENVIRONMENTAL PROTECTION AGENCY
                 Office of Air, Noise, and Radiation
              Office of Air Quality Planning and Standards
              Research Triangle Park, North Carolina 27711


                     February 1982

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This report has been reviewed by the Emission Standards and Engineering Division of the Off ice of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended tc
constitute endorsement or recommendation for use. Copies of this report are available through the Library Service
Office (MD-35), U. S. Environmental Protection Agency, Research Triangle Park, N. C. 27711, orfrom National Technics
Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.

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                       TABLE OF CONTENTS
                                                         Page
Chapter 1.   INTRODUCTION	     1
Chapter 2.   SUMMARY OF CHANGES  SINCE  PROPOSAL
Chapter 3.   SUMMARY OF PUBLIC COMMENTS  AND  RESPONSES.  .     4
            Table 1.   LIST OF COMMENTERS	    16

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                              CHAPTER  1
                            INTRODUCTION
      On October  15,  1980,  the U. S.  Environmental Protection
 Agency published in  the Federal Register (45 FR 68514) revisions
 to Methods 101 and 102, "Determination of Particulate and
 Gaseous Mercury Emissions  from Chior-Alkali Plants - Air Streams,"
 and "Determination of Particulate and Gaseous Mercury Emissions
 from Chlor-Alkali Plants - Hydrogen Streams," respectively, and
 a new Method 111, "Determination of Particulate and  Gaseous Mercury
 Emissions  from Sewage Sludge Incinerators."  Method  111  has been
 redesignated as Method 101A.   These revised methods  and  new method
 were  proposed under the  authority  of  Sections  112, 114,  and 301(a)
 of the  Clean  Air  Act,  as amended.
      Public  comments  were  solicited at  the  time  of proposal.  To
 provide interested  persons  the opportunity  for oral  presentation
 of data, views, or  arguments  concerning the  proposed  revisions and
 test methods, a public hearing was scheduled for November 6, 1980,
 at  the Research Triangle Park, North  Carolina, but no person
 desired to make an oral presentation.   The public comment period
was from November 6,  1980,   to December 15, 1980, and was extended
to February 13, 1981.
     Five comment letters were received concerning issues relative
to the proposed test methods.  A detailed  discussion  of these
comments and responses are  summarized  in this document.   The summary
of comments and responses serves  as the basis for the revisions  which
have been  made to the test  methods  between proposal  and  promulgation.

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                                 CHAPTER 2
                    SUMMARY OF CHANGES SINCE PROPOSAL
Method 101
     1.  Section 4.2.  A performance specification has been added
to allow the use of acceptable alternative equipment and procedures.
     2.  Section 5.3.  Criteria for accepting alternative analysis
apparatus are added.
     3.  Section 5.3.2.  Asbestos insulation tape is replaced with
fiberglass insulation tape.
     4.  Section 5.3.9.  Dry, mercury-free air is included as an
option for the aeration gas.
     5.  Section 6.2.2.  It is specified that all mercury standard
solutions be prepared in borosilicate glass containers.
     6.  Section 7.1.3.  The asbestos string gasket used with the
probe nozzle is replaced with a fiberglass string gasket.
     7.  Section 7.3.2.  The first sentence has been reworded to
provide technical clarity.
     8.  Section 8.3.  The option to measure the mercury response by
                                           m
either peak height or peak area is added.
     9.  Section 9.4.  CH ,*„} was corrected to represent total
nanograms of mercury in the aliquot analyzed as opposed to the final
mercury concentration.
Method 101A
     1.  Section 4.  A performance specification has been added to
allow the use of acceptable alternative equipment and procedures.

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     2.   Section 6.2.5.   It is specified that all  mercury standard
solutions be prepared in borosilicate glass containers.
     3.   Section 7.1.1.   Two runs are collected to make  one sample
where an excess of water condensation is encountered.
     4.   Section 7.2.1.   The first three impingers are included in the
KMnO, rinse for mercury recovery.
     5.   Section 8.3.  The option to measure the mercury response by
either peak height or peak area is added.

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                                 CHAPTER 3
                 SUMMARY OF PUBLIC COMMENTS AND RESPONSES
Method 101
1.  D-2
     Comment:  Method 101A uses KMnO, as the absorbing medium.   We
have extensively and successfully employed KMnO^ to determine Hg
concentrations in gaseous and aqueous streams.   We recommend that
KMnO, be specified as an acceptable alternative to IC1 for use in
the collecting liquids for Methods 101 and 102.
     Response:  IC1  was specified for chlor-alkali plants because the
literature indicates that IC1  is a better oxidizing agent for elemental
Hg and a more stable reagent than KMnO*.  Chlor-alkali plants primarily
emit elemental Hg, while sludge incinerators emit Hg compounds.   Thus
a strong, fast acting oxidizing reagent is needed for chlor-alkali
plants but not sludge incinerators.   However,  this does not mean that
KMnO, is unacceptable for chlor-alkali plants.   If comparative data
are made available to EPA,  consideration will  be given to the use of
KMnO* for chlor-alkali plants.
2.  D-4
     Comment:  Paragraph 7.3.2  is confusing.  What is the rationale
for pipetting separate flasks?   We believe that separate aliquots from
the same flask would be satisfactory.  Also, why is it necessary at
all to dilute at this point?  This technique would reduce sensitivity
by a factor of 100.

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     Response:   The first two sentences in the paragraph have been
corrected to read, "Pipet a 2-ml  aliquot from the diluted sample
(from Section 7.3.1)  into a 250-ml  volumetric flask.   Add 10 ml  of 5 percent
H2SO. and adjust the  volume to exactly 250 ml with deionized
distilled water."  This dilution  step is necessary to reduce the
IC1 concentration to  a level  that will not inhibit Hg reduction  in
the aeration cell and to bring the Hg concentration within the range
of the AA.
3.  D-2, D-3, D-4
     Comment:  Errors in the following sections should be corrected:
          a.  5.1.2  Temperature  should be 120 instead of 12.
          b.  5.1.3  "Lead-free"  should be "Leak-free."
          c.  5.3.9  Omit the slash between nitrogen and cylinder.
          d.  6.2.5  Reference to 7.2.5 should be changed to
              7.2.3.
          e.  9.4  (1) Use the calibration curve and these corrected
                       averages,  to determine the total weight of
                       mercury in nanograms  in the aeration cell
                       for each source sample, not concentration.
                   (2) In Section 9.4, MH  should be mH  .
                   (3) Under Eq.  101-1, add:  "where:  CH (Acj = Total
                       nanograms of mercury  in aliquot analyzed
                       (reagent blank  subtracted)," and  change
                       D.F. = 250/2  if the source  samples were diluted
                       as described  in Section 7.3.2,  not 7.3.3.

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                    (4) Eq. 101-2 uses R for emission  rate and  K


                       for gas constant.  The gas constant is


                       universally designated R.



                    ^ V Vm(std)> andVw(std) 1nEc>- 101-2 should


                       be defined.


     Response:  These corrections have been made.   K  is not a gas


constant but a numerical/dimensional constant.  The terms in item (5)


are defined in Sections 9.1, 9.2, and 9.3.


Method 102


4.  D-2


     Comment:   In 2.3, add the word "mixture" after the word


"explosive."


     Response:  This suggestion has been incorporated.


Method 101A


5.  D-l
                          /

     Comment:   The sampling procedure as set forth by Method 101 A, in


general,  is viewed as satisfactory.
                                          *

     Response:  No response needed.


6.  D-l


     Comment:   The change from IC1  to KMnO,  is viewed as favorable.


KMnO,  can be obtained in  purer form than IC1,  thus allowing for a


lower Hg  concentration in the blank.


     Response:  No response needed.

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7.  D-l
     Comment:  The use of KMnCL as a rinse of the probe nozzle, probe
fitting, probe liner, and front half of the filter holder would be
quite messy and would tend to increase the mercury in the sample if
the KMnCL is contaminated.  Perhaps it would be wise to consider using
8 N HC1 as the rinse since it would be more effective in removing
residual brown deposits and is less messy than KMnCL.
     Response:  KMnCL is not used in the front half of the train during
sampling, so no brown deposit is formed.  The use of KMnCL is preferred
over 8 N HC1  because it is less caustic and can better oxidize and
remove mercury deposits left from the previous sample.   The blank would
reveal  whether the KMnO^, was contaminated.
8.  D-l
     Comment:   The use of a stainless steel  wire screen is highly
recommended as opposed to a glass frit support for the same reason as
stated in the proposed revisions.
     Response:  No response needed.
9.  D-4, D-5
     Comment:   The use of a stainless steel  wire screen ignores the
possibility of loss of mercury through amalgamation or adsorption on
the wire screen.
     Response:  The use of a filter in this method is optional to
accommodate sources with high particulate loading.  At these sources,
essentially all Hg emissions are in the compound form.   Glass frits
were found to be a source of cross contamination and are, therefore,
unacceptable.
                                    7-

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Methods 101. 101A, and 102
Analytical Alternatives
10.  D-l, D-4, D-5
     Comment:  The EPA Method 245.1 from Methods for Chemical Analysis
of Water and Wastes (EPA 600/4-79-020) should be incorporated as the
preferred analytical method.  This procedure is well documented and
established as producing precise and accurate results.   Most
laboratories involved in stack testing will have the equipment and
expertise to routinely perform this analysis.
     Response:   This method is not equivalent to the Method ,101A
procedure in relation to important dilutions and reagent volumes.
Some deficiencies have been found in the analytical apparatus that
are resolved in Method 101A (discussed in Citation 16 of Method 101).
The need to condition and periodically replace the desiccant, Hg
losses experienced in the BOD bottle,  and the technique required to
perform this procedure make it less desirable than Method 101A.
11.   D-4,  D-5
     Comment:   Section 5.3.1 specifies a Parkin-Elmer 303 AA or
equivalent.   Since the 303 AA is  a versatile spectrophotometer,  the
phrase "or equivalent" eliminates the  possibility of using one of  the
commercially available instruments specifically designed for determining
Hg by flameless AA.   They are equal  to or superior to the 303 for  the
analysis of Hg  and are much less  expensive.

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     Response:  Substitution of such commercially available systems
is allowable as long as they meet the calibration and analytical
precision and accuracy specified in the method.   The following
guidelines will be added to the method.
     a.  The reducing agent should be added after the aeration cell
is closed.
     b.  The aeration bottle bubbler should not contain a frit.
     c.  Any Tygon used should be as short as possible and conditioned
prior to use until blanks and standards yield linear and reproducible
results.
     d.  If manual stirring is done before aeration, it should be
done with the aeration cell closed.
     e.  The system must be demonstrated to have accuracy and precision
equivalent to the method (done through replicate analyses of spiked
samples and/or analysis of samples of known concentration obtained from
a reliable source).
     f.  A drying tube should not be used unless it is conditioned as
the Tygon above.
12.  D-2
     Comment:  Certain other methods than atomic absorption
spectrophotometry for analyzing the absorbing solution are acceptable
alternatives and should be allowed.   It is recommended that direct
current argon plasma emission spectrometry (APES) be included in the
test methods as an alternative to atomic absorption.  Attached is a
reprint which elaborates on the use of APES.
                                     9-

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       Response:  Alternative methods  are allowed  on  a  case-by-case  basis.
  In the case of the APES method, the  level of operator skill
  and equipment needs are much higher  than most companies will have
  available.  It is a sophisticated technique that yields results very
  sensitive to operator technique and, therefore, is not readily adaptable
  at this time to routine, widespread use.
  Variations in Equipment Specifications
  13.   D-2, D-4, D-5
      Comments:   (a)  Variations  in  the dimensions  of the  optical  cell
 should be allowed  because:   (1)  calibration  with  a given  cell  adjusts
 for  its  peculiarities.   (2)  The  dimensions  specified do  not coincide
 with  cells in  commercially  available instruments.   (3) The  large
 diameter  (3.81  cm) of  the optical  cell  reduced  mixing  and sensitivity,
 both  of which  lead to  poorer analysis.  (4)  The aeration  flask specified
 is fragile and would be  very difficult  to clean properly.   It would be
 a major problem in routine  use.  (5)  Some commercially available
 instruments use a recirculating, rather than a  flow-through  system.
 Studies reported in the  literature have shown recirculating  systems
 to be  as valid as the once through system.  Since  the absorbance is read
 when the Hg concentration reaches equlibrium, there  is no need for a
 recorder,.
     (b) Alternative heating devices should be allowed because:   (1) Other
 devices achieve the same effect.   For example,  infrared lamps have
 been used.  The Agency 245.1 allows the use of a desiccant and a 60-
watt incandescent lamp to prevent condensation  in  the optical cell.
                                      10

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 (2) Moisture condensation is not normally a problem, and, therefore,
 heating the optical cell is not necessary; this may be a particular
 problem resulting from the proposed large diameter optical  cell.
      (c) The use of flexible Tygon  tubing should be allowed as an
 alternative to glass in the aeration cell-to-optical  cell  conncection
 for the following reasons:   (1)  The EPA allows  its use in Method 245.1
 for Hg  analysis of water and wastes.   (2)  Flexible tubing is  necessary
 for some of the comercially available systems.   (3)  The  standard
 practice of daily conditioning  the  system  with  5 to  10 yg of  Hg
 eliminates  any problems resulting from the choice of  tubing.
 (4)  Use  of  flexible tubing  allows for mixing by  swirling  the  aeration
 flask and eliminates  the  need for a magnetic stirrer.  Silicone
 tubing  has  been  found  to  be  completely  satisfactory,  too.
     Response:   The analytical equipment described in  Methods  101,
 101A, and 102  (aeration bottle, all  glass  tubing  connection,  single
 pass system, optical cell heating)  is  significantly different  from
 that allowed in  EPA 245.1.  The equipment was designed to minimize
                                             f
 imprecision and  inaccuracy in the analysis.  Maximum accuracy  and
 precision is necessary  because of sampling costs and the dilutions
 required to bring the sample concentration into the range of the
 flame AA. 'Method 101 is more accurate and precise than EPA 245.1
 as can be seen by comparison of the  precision and accuracy of  both
methods.
                                      n

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     However, since the research' on Methods 101  and 102, commercially
available systems have been developed that are just as accurate and
precise.  Therefore, substitution of these systems will be allowed
as long as they meet the guidelines stated in the response to
Comment 11.
Miscellaneous
14.  D-2
     Comment:  The proposed changes will  improve the accuracy and
precision of the sampling and analysis methods.
     Response:   No response needed.
15.  D-4, D-5
     Comment:  The use of nitrogen is not essential.  Dried,  filtered,
Hg-free air  is  adequate.
     Response:   We agree.  Section 5.3.9  has been revised to  read,
"Aeration Gas Cylinder.  Nitrogen or dry, Hg-free air, equipped with
a single stage  regulator."
16.  D-4, D-5
                                          *
     Comment:  The use of an asbestos gasket with the probe nozzle
and asbestos insulation tape is inconsistent with the Agency's position
relative to  the use of asbestos substitute materials.  Many
laboratories have abandoned use of these  products.
     Response:   Fiberglass tape may be substituted.  Sections 5.3.2 and
7.1.3 have been revised to read "fiberglass tape" and "fiberglass
gasket," respectively.
                                       12

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 17.   D-4,  D-5
                                 *.
      Comment:   For  the  flow-through  system, measurement of the peak
 area  is  far more  precise and sensitive than the peak height.  This
 also  eliminates the need for precise control of temperature and
 volume.
      Response:  Our data showed that either peak height or area was
 acceptable.  Either may be used.  The following sentence will be
 added to the beginning of Section 8.3:  "The mercury response may
 be measured by either peak height or peak area."
 18.  D-4
     Comment:   The Method of Standard Additions should be detailed in
 some way, perhaps as an appendix.
     Response:   The method is described in Citation 19 of Method  101.
 19.  D-3
     Comment:   Why is the source sample initially diluted  with
deionized distilled water?  This only serves to decrease the sensitivity
of the test.   If all rinses were done with 0.1  M Id  and the total
volume was  then measured,  a 2-ml aliquot  of sample diluted to 250 ml
as described  in the second dilution  step  would  yield  a 0.0008 M IC1
solution.  If  a 5-ml aliquot of this solution was  pipetted into the
aeration flask  (containing 50 ml of  deionized water),  the  final
solution would  be 0.00008  M IC1, which would not inhibit the reduction
of Hg.
                                    13

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      Response:  These dilutions are needed to bring the sample
                                s
 concentration into the range of the spectrophotometer.  In doing
 so, an accurate initial  volume is needed.  The source sample volume
 after recovery is approximately 550 to 600 ml.   Because the density
 of this solution is uncertain after collection,  weighing is not a
 suitable method of determining volume.   Similarly,  the graduations on
 a 0 to 1000 ml graduated cylinder that would  be  needed (if dilution
 in a volumetric flask is not done)  would be too  large  for  accurate
 measurement.
 20.   D-3
      Comment:   It  would  be  helpful  to  state the minimum  total ng
 detectable  in  the  aeration  cell.  This  works  out to about  20 ng.
      Response:  This  depends  upon the sensitivity of the system.
 21.   D-4
      Comment:  We  recommend  that the mercury  stock solution be stored
 in and pipetted into  borosilicate glass bottles, and not plastic
 bottles.
     Response:  This  has been incorporated into the method.
 22.  D-3
                                                  «
     Comment:   In cleaning glassware, the Preparation  of Sampling
Train Section and the Calibration and Standards Section do  not agree.
The procedure in the latter section  of prolonged  soaking with
50 percent nitric acid should be the first step in  cleaning glassware.
                                      14

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     Response:  Equipment in the Preparation of Sampling Train
Section is not soaked because this would be difficult for probes.
Recovery studies have shown that the specified rinsing is an
acceptable method for avoiding contamination.   Also,  the washing
procedure is done after each sample while the  sample  recovery for
the previous run is being performed.
                                      15

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                  TABLE  1.   LIST OF  COMMENTERS
                       Docket No. A-79-45
 Document Number

 IV-D-1
IV-D-2
IV-D-3
IV-D-4
IV-D-5
       Commenter/Aff111ation

 Donald  L.  Dustin, Jr., Manager, Stack Testing
 Ecology and  Environment, Inc.
 195  Sugg Road
 Post Office  Box D
 Buffalo,  New York 14225

 J.C, Brown,  Manager,  Environmental Technology
 01 in Chemicals Group
 Post Office  Box 243
 Charleston,  Tennessee 37310

 Barbara  Dell/Acqua,  Associate Chemist
 New York State Department of Environmental
   Conservation
 50 Wolf  Road
 Albany,  New  York 12233

 Edmund J. Laubusch,  Technical Manager
 The Chlorine Institute,  Inc.
 342 Madison Avenue
 New York, New York 10173

 Richard J. Samel son,  Manager, Environmental
  Programs
PPG Industries,  Inc.
One Gateway Center
Pittsburg, Pennsylvania  15222
                                      16-

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing;
1. REPORT NO. 2
EPA-450/3-82-008
4. TITLE AND SUBTITLE
Revisions to Methods 101, 101A, and 102 for
Determination of Mercury Emissions
Summary of Comments and Responses
7 AUTHORfS)
Emission Standards and Engineering Division
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Measurement Branch (MD-19)
Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards (MD-10
Office of Air, Noise, and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
February 1982
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO. ;
f
13. TYPE OF REPORT AND PERIOD COVEREr ,'
}
14. SPONSORING AGENCY CODE
EPA/200/04
15 SUPPLEMENTARY NOTES
16. ABSTRACT
This document addresses the public comments s
of the mercury methods in the Federal Register. Ch
as a result of these comments are included. This <
basis for the revisions which have been made to th<
proposal and promulgation.
jbmitted after proposal
anges made to the methods
document serves as the
3 test methods between
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.lDENTIFI

18 DISTRIBUTION STATEMENT 19. SECURT
Release Unlimited Uncla
20. SECURI-
Uncla
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
ERS/OPEN ENDED TERMS C. COSATI Field/Group
13B
FY CLASS (This Report) 21. NO. OF PAGES
ssified 20
PY CLASS (This page) 22. PRICE
ssified


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