U.S. Environmental  Protection  Agency
                                                    •ificatio
                                                                                ET
         Mercury Continuous Emission Monitors (OEMs)
The U.S. EPA Environmental Technology Verification
(ETV) Program's Advanced Monitoring Systems (AMS)
Center, operated by Battelle under a cooperative agreement
with EPA, has verified the performance of seven continuous
emission monitors1 (CEMs) for measuring mercury
emissions (Figure 1). Four additional monitoring
technologies are currently in testing with reports to be final
in early 2007. To address the health effects caused by
mercury emissions from coal-fired plants, EPA recently
issued the Clean Air Mercury Rule (CAMR).  This rule
requires coal-fired power plants, the largest remaining
unregulated source of human-generated mercury emissions
in the U.S., to reduce mercury emissions. The rule also will
require power plants to monitor their mercury emissions
using technologies like those verified by the ETV Program.

                           Technology Description
                           and Verification Testing

                           CEMs for mercury are a rela-
                           tively new technology
                           category. They offer an
                           advantage over conventional
                           laboratory techniques (e.g.,
                     ^^! the Ontario Hydro method) in
                      ^" that they can provide
                           continuous or frequent results
                           through sequential readings  at
                           intervals of several minutes,
                           , labor, and cost associated
    One of the test locations for
    mercury CEM verification
                                                              Mercury and Its Regulatory
                                                                Background at a Glance

                                                       Mercury is a toxic, persistent pollutant mat,
                                                       after deposition from the atmosphere and
                                                       methylation bioaccumulates in the food
                                                       chain, particularly in fish. Mercury can cause
                                                       adverse neurological health effects,
                                                       particularly in young children and the unborn
                                                       children of mothers who eat food
                                                       with significant quantities of mercury.

                                                       The Clean Air Mercury Rule (CAMR), which
                                                       EPA issued on March 18, 2005, creates
                                                       a market-based cap-and-trade  program that
                                                       will reduce nationwide utility  emissions of
                                                       mercury. Under a cap-and-trade program, coal-
                                                       fired power plants that reduce emissions more
                                                       than is required receive allowances. They can
                                                       then trade these allowances to sources that are
                                                       unable to meet the requirement, or bank them
                                                       for future use.

                                                       A cap-and-trade program, like that under
                                                       the CAMR, must include reliable monitoring
                                                       of emissions to ensure that reductions occur,
                                                       allow for tracking  progress, and lend
                                                       credibility to the trading component of the
                                                       program. Therefore, the CAMR requires coal-
                                                       fired utilities that emit more than 29 pounds of
                                                       mercury per year to collect mercury emission
                                                       data continuously. To collect these data, the
                                                       utilities can use either CEMs,  like those
                                                       verified by the  ETV Program, or another long-
                                                       term mercury sampling method, a sorbent trap
                                                       monitoring approach.
and thus, they avoid the delay
with laboratory methods.

The ETV-verified CEMs determine elemental mercury
vapor concentrations by atomic absorption (AA), atomic
fluorescence (AF), or plasma atomic emission (AE).  The
CEMs use aqueous reagents or heated catalysts to reduce
oxidized forms of mercury to elemental mercury for
detection, allowing measurement of total vapor-phase
mercury. Although some CEMs only measure total vapor-phase mercury (i.e., the sum of elemental and
oxidized mercury vapor), others allow separate measurement of the elemental and oxidized forms. Table 1
summarizes some of the performance  data for the verified technologies.  Additional information on the
verification of mercury CEMs can be found at http://www.epa.gov/etv/verifications/vcenterl-ll.html.

The verification testing was conducted in two phases. In the first phase, four of the technologies were tested
under conditions simulating a) coal-fired flue gas, and b) municipal incinerator flue gas.  The tests took place at
a pilot-scale incinerator in Research Triangle Park, North Carolina, over a three-week period. In the second
phase, five technologies (including two of the technologies tested in the first phase) were evaluated at a foil-
                             scale hazardous waste incinerator
                             in  Oak Ridge, Tennessee.  In
                             addition, the ETV Program is
                             currently conducting a third
                             phase of testing at a coal-fired
                             power plant. The box on the right
                             identifies CEMs and sorbent-
                             based sampling technologies
                             included in this third phase.
ETV Advanced Monitoring
     Systems Center

    Robert Fuerst, EPA
   fuerst.robert (glepa.gov
    Tel: (919) 541-2220
   Amy Dindal, Battelle
   dindala@battelle.org
   Tel: (561) 422-0113

                                                              Mercury Monitoring Technologies
                                                              Included in the Third Phase of
                                                              ETV Verification
                                                              Tekran Instruments, Series 3300 Mercury CEM
                                                              Thermo Electron, Mercury Freedom System
                                                              Environmental Supply Company, HG-324
                                                                 sorbent-based sampling system
                                                              Apex Instruments, mercury sorbent-based
                                                                 sampling system
 The ETV Program operates largely as a public-private partnership through competitive cooperative agreements with non-profit research institutes. The
program provides objective quality-assured data on the performance of commercial-ready technologies. Verification does not imply product approval or
effectiveness. ETV does not endorse the purchase or sale of any products and services mentioned in this document.

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    Selected Outcomes of Verified
      Mercury CEM  Technologies

 •  Contributed to advancing mercury
    monitoring technology and resulted in
    improvements in monitors by the
    participating vendors

 •  Helped inform the development of the
    CAMR and could assist in future rule
    refinements

 •  Helped small vendors compete in the
    marketplace

 •  Verification of the mercury CEMs
    involved significant collaboration
    with state agencies (e.g.,
    Massachusetts and  Connecticut), the
    Department of Energy and Illinois
    Clean Coal Institute. These
    collaborations resulted in the sharing
    of scientific expertise among the
    agencies and enabled smaller vendors
    to participate in the tests.
                                                    Fig 1. ETV-Verified CEMs for Mercury (First Two Phases of Testing)
Envimetrics, Argus-Hg 1000 Mercury CEM:
Uses AE spectroscopy with a proprietary catalytic
converter that reduces molecular forms of
mercury to atomic mercury. Total mercury can be
measured during automatic operation, or both
total and elemental mercury can be measured
when manually operated.


  Nippon Instruments Corporation, DM-6/
  DM-6P Mercury CEM: Uses cold vapor
  AA with a catalytic process to measure
  total mercury.

  Nippon Instruments Corporation, AM-2
  Elemental Mercury CEM: Uses cold vapor
  AA, with a distilled water scrubbing trap  for
  removal of any oxidized mercury species, to
  measure elemental mercury.
    OPSIS AB, HG-200 Mercury
    CEM: Uses a double-beam pho-
    tometer to measure total or ele-
    mental mercury with a thermo-
    catalytic converter that forms
    elemental mercury from any
    oxidized mercury compounds to
    measure total mercury.


  PS Analytical, Ltd.,  Sir Galahad II
  Mercury CEM (verified in both
  phases): Uses AF to provide
  separate and continuous
  measurement of elemental and total
  mercury with a proprietary aqueous
  reagent to convert oxidized mercury
  to elemental mercury for total
  mercury measurement.
 Nippon Instruments Corporation, MS-1/
 DM-5 Mercury CEM (verified in both
 phases): Uses cojd vapor AA to provide
 separate and continuous measurements of
 elemental and oxidized mercury, which are
 separated using a wet scrubbing and
 chemical reaction system.
CEM: Uses cold vapor AA to provide
separate and continuous measure-
ments of elemental and total mercury,
with catalytic pyrolysis to decompose
oxidized mercury to elemental mercury
for total mercury measurement.
                                                The price of the monitors ranged from $30,000 to $70,000 at the time of testing.
Table 1. Selected Performance of Verified CEMs for Mercury
Technology*
Average Relative
Accuracy, %
Relative
Precision, %
Response
Time (95%)
Bias, %

Correlation6
Slope
Intercept
r2
Data
Completeness

First Phase
A
B
C (Phase I)
D (Phase I)
58.2 to 71%
(total mercury)
14 to 23%
(elemental
mercury)
20.6 to 32.8%
(total mercury)
13.2 to 39.1%
(total mercury)
2.5 to 27%
3 to 40.3%
1.8 to 24.7%
3.7 to 23.9%
30 to 100
seconds
One 13-minute
cycle
One 5- to 6-
minute cycle
35 to 50 sec-
onds
-44.5 to -20.5%
7%
-4.9 to -0.3%
-7%
not re-
ported
0.885
0.681
0.607
not reported
-0.212
2.492
3.92
0.621
0.973
0.978
0.938
Not estimated
100%
100%
100%
Second Phase
C (Phase 1 1)
D (Phase II)
E
F
G
59.8%
(total mercury)
11.2%
(total mercury)
76.5%
(overall)
20.3%
(overall)
76.3%
(overall)
8.9 to 15.9%
9.2 to 17.3%
10.1 to 22.1%
9.1 to 10.9%
12. 5 to 43. 3%
One 5- to 6-
minute cycle
2 to 3 minutes
One7-minute
cycle
2 minutes
One5-minute
cycle
2.8 to 6.9%
0.0 to 6.6%
0.3 to 14.6%
0.0 to 13. 6%
Not
evaluated
0.4973
0.899
0.3404
0.8347
0.3559
6.8904
2.4969
9.4121
3.5033
8.1695
0.875
0.987
0.839
0.953
0.935
88.3%
97.7%
92.7%
97.5%
65.8%
A Because the ETV Program does not compare technologies, the performance results shown in this table do not identify the vendor associated with each result and are not in
the same order as the list of technologies in Figure 1 .
B Correlation data shown are for total mercury, except technology B, where results shown are for elemental mercury.
Note: In each phase of verification testing, the Ontario Hydro method was used as the reference method for establishing the performance of the tested technologies. The
performance parameters verified included the following: accuracy relative to the Ontario Hydro method, correlation with that method, precision (i.e., repeatability), bias, cali-
bration/zero drift, response time, interferences, data completeness, and other operational factors. The ETV Program found that the average relative accuracy for the monitors
ranged from 11. 2 to 76.5%. A result of 0% indicates perfect accuracy relative to the reference mercury concentration. The relative precision ranged from 1.8 to 43.3%. A
result of 0% indicates perfect precision. A higher r2 value indicates a h gher correlation with the standard test method over the range of concentrations tested.
References

U.S. EPA, Mercury, http://www.epa.gov/mercury/.

U.S. EPA, 2006. ETV Case Studies: Demonstrating Program Outcomes. Volume II.
  EPA/600/R-06/082. September 2006. (Primary source)

U.S. EPA, ETV, http://wmv.epa.gov/etv/.
                                                      EPA/600/S-07/006
                                                          January 2007

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