THE ENVIRONMENTAL TECHNOLOGY VERIFICATION PROGRAM
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  U.S. Environmental Protection Agency                  I ^y ^^ I              7"e BuSmeSS O/ Innovation
                                     Illinois Clean Coal Institute
                    ETV Joint Verification Statement
      TECHNOLOGY TYPE:  Mercury Emissions Monitor

      APPLICATION:         Monitoring of Flue Gas Mercury

      TECHNOLOGY
      NAME:                 Series 3300 Mercury Continuous Emissions Monitoring
                              System

      COMPANY:             Tekran Instruments Corporation

      ADDRESS:              230 Tech Center Drive        PHONE: (865) 688-0688
                              Knoxville, TN 37912          FAX:

      WEB SITE:             www.tekran.com
      E-MAIL:                sales@tekran.com
The U.S. Environmental Protection Agency (EPA) has established the Environmental Technology Verification
(ETV) Program to facilitate the deployment of innovative or improved environmental technologies through
performance verification and dissemination of information. The goal of the ETV Program is to further
environmental protection by accelerating the acceptance and use of improved and cost-effective technologies.
ETV seeks to achieve this goal by providing high-quality, peer-reviewed data on technology performance to
those involved in the design, distribution, financing, permitting, purchase, and use of environmental
technologies. Information and ETV documents are available at www.epa.gov/etv.

ETV works in partnership with recognized standards and testing organizations, with stakeholder groups
(consisting of buyers, vendor organizations, and permitters), and with individual technology developers. The
program evaluates the performance of innovative technologies by developing test plans that are responsive to
the needs of stakeholders, conducting field or laboratory tests (as appropriate), collecting and analyzing data,
and preparing peer-reviewed reports. All evaluations are conducted in accordance with rigorous quality
assurance (QA) protocols to ensure that data of known and adequate quality are generated and that the results
are defensible.

The Advanced Monitoring Systems (AMS) Center, one of six technology areas under ETV, is operated by
Battelle in cooperation with EPA's National Exposure Research Laboratory. In collaboration with the Illinois
Clean Coal Institute, and with assistance from the Northern Indiana Public Service Company, the AMS Center

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evaluated the performance of the Tekran Instruments Corporation Series 3300 Mercury Continuous Emissions
Monitoring (CEM) System for determining mercury in stack gas at a coal-fired power plant. This verification
statement provides a summary of the test results.

VERIFICATION TEST DESCRIPTION

The performance of the Series 3300 CEM was evaluated in terms of relative accuracy (RA), linearity, seven-day
calibration error, cycle time, data completeness, and operational factors (ease of use, maintenance and data
output needs, power and other consumables use, reliability, and operational costs). RA was determined
according to Equation A-10 of Chapter 40 of the Code of Federal Regulations Part 75 (40 CFR Part 75)
Appendix A, by comparing CEM vapor-phase mercury results to simultaneous results from American Society
for Testing and Materials D 6784-02, the "Ontario Hydro" (OH) method. RA of the Series 3300 was  determined
for total mercury (HgT) and elemental mercury (Hg°). Linearity was determined based on Series 3300 responses
to Hg° standards. Calibration error was evaluated by comparing Series 3300 readings on mercury standard and
zero gases performed once each day over a consecutive seven-day period. Cycle time was evaluated in terms of
the response of the Series 3300 when switching from a zero gas or upscale Hg° standard gas, supplied at the
Series 3300 inlet, to sampling of stack gas. Data completeness was assessed as the percentage of maximum data
return achieved by the  Series 3300 over the test period. Operational factors were evaluated by means of
observations during testing and records of needed maintenance, vendor activities,  and expendables use.

The Series 3300 was verified at Unit 17 of the R.M. Schahfer Generating Station,  located near Wheatfield,
Indiana, between June  12 and July 25,  2006. Unit 17 burns pulverized Illinois sub-bituminous coal and has an
electrostatic precipitator and a wet flue gas desulfurization unit. Twelve successive OH method runs, each of
2 hours duration, were  conducted on the Unit 17 stack in each of two separate reference sampling periods using
paired OH trains. Those reference samples were collected and analyzed for Hg° and oxidized mercury (Hg0x),
the sum of which is HgT.

QA oversight of verification testing was provided by Battelle and EPA. Battelle QA staff conducted a technical
systems audit, a performance evaluation audit, and a data quality audit of 10% of the test data.

This verification statement, the full report on which it is based, and the test/QA plan for this verification test are
all available atwww.epa.gov/etv/centers/centerl.html.

TECHNOLOGY DESCRIPTION

The following description of the  Series 3300 CEM is based on information provided by the vendor. The
information provided below was  not verified in this test.

The Series 3300 measures HgT, Hg°, and Hg0x in combustion sources. It is designed to  be insensitive to the
presence of sulfur dioxide, nitrogen oxides, carbon monoxide, hydrogen chloride (HC1), and other common
combustion by-products and to operate unattended for extended periods. In this verification the Series 3300 was
programmed to report a reading of mercury concentration every 2.5 minutes. The  CEM alternated
measurements of HgT and Hg°, providing two successive readings of HgT, followed by two of Hg°, two of HgT,
etc.

The Series 3300 consists of a sampling probe,  a heated umbilical line, a dual channel sample conditioner, a
mercury analyzer, a saturated Hg° vapor calibration source, and a control system.  It uses a stack-mounted
inertial probe to minimize mercury  measurement artifacts due to filtering. The probe can perform automated
filter blowback, multi-point calibrations, and standard additions of mercury into the sample matrix. The sample
flow from the probe is  diluted and sent at a high rate through the heated umbilical line to the sample
conditioning module, which speciates the mercury into elemental and oxidized forms without using chemical

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reagents or solid sorbents. In one channel, a thermal conditioner unit converts all mercury forms into Hg°, and is
designed to avoid recombination by the quantitative removal of HC1 and other gases. The second channel
removes Hg0x, leaving only the Hg° to pass through to the converter. This stream is then subjected to additional
conditioning to remove acid gases and excess humidity from the sample. The two conditioned streams are
analyzed by a Tekran Model 2537A mercury vapor analyzer using gold preconcentration combined with atomic
fluorescence detection.

All temperatures, flows, and pressures are displayed by the control system and may be set by authorized users.
The system features remote operation and problem diagnosis. The Series 3300 can be audited by introduction of
mercury calibration gas standards, which can be delivered directly to the probe inlet by the umbilical line.

The Series 3300 component rack system is approximately 67 inches high by 31.5  inches deep by 23 inches
wide. The associated air purification system occupies a wall-mountable panel 24 inches by 24 inches in size.

VERIFICATION  RESULTS

The RA of the Tekran Series 3300 CEM was 18.5% for HgT and 15.4% for Hg°, based on comparison to  12 OH
reference results obtained at the start of the six-week field test. The overall average HgT, Hg°, and Hg0x values
from that first set of OH data were 0.815, 0.768, and 0.047 microgram per dry standard cubic meter (ug/dscm),
whereas those from the Series 3300 were 0.923, 0.849, and 0.074  ug/dscm, with resulting differences of 0.108,
0.081, and 0.027 ug/dscm, respectively. The RA of the Series 3300 was 28.7% for HgT and 27.8% for Hg°,
based on comparison to nine OH reference results obtained at the  end of the six-week field test. The overall
average HgT, Hg°, and Hg0x values from that set of OH data were 1.011, 0.948, and 0.060 ug/dscm, whereas
those from the Series  3300 were 0.805,  0.735, and 0.098 ug/dscm, with resulting differences of 0.206, 0.213,
and 0.038 ug/dscm, respectively.

The linearity error of the Series 3300 was 4.7 to 6.9% when tested over the range  of about 1 to 4.5 ug/dscm and
1.6 to 5.7% when tested over a range of about 4 to  16 ug/dscm.

The seven-day calibration error of the Series 3300 was evaluated with zero gas and with a calibration gas of
about 4.5 ug/dscm Hg°. Error in zero readings ranged from 5.75 to 14.6% of span, and error in calibration gas
readings from 0.66  to 3.14% of span, in both cases relative to an assumed 10 ug/dscm span value.

Cycle time of the Series 3300 was estimated to  be 7.5 to 10 minutes, in switching from either zero gas or span
gas to sampling of stack gas. The Series 3300 provided a mercury reading every 2.5 minutes, so  the cycle time
was estimated as a multiple of this integration time.

Data completeness  of the Series 3300 was 99.9% over the six-week field test, in the sense that the CEM
operated with minimal down time and provided readings at 2.5-minute intervals throughout the test. However,
not all readings were valid measurements of stack gas mercury. Frequent erroneous readings of 0 ug/dscm were
reported by the Series 3300 in a portion of the field period, amounting to 8.1 days of such readings (18.6% of
the field test duration).

The Series 3300 used one standard cylinder of argon (about 200 cubic feet of gas) in about one month of
continuous operation. The Series 3300 also used deionized water at a rate of about 3 liters per day; required
both 240 and 120V AC power, with connections for the latter both at the ground and aloft at the  stack sampling
port; and required connection to facility compressed air.  The Series 3300 is controlled by software that can be
accessed locally or  remotely and provides rapid control of all instrument operations and detailed information on
mercury results and instrument functions. The only recurring problem with the Series 3300 was the frequent
reporting of 0 ug/dscm for stack gas mercury over approximately  two weeks of the field period.  This problem
apparently was related to the ultraviolet lamp in the mercury analyzer of the Series 3300 and was ultimately
solved by replacement of the lamp and proper adjustment of lamp voltage.

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The cost of the Tekran Series 3300 Mercury CEM as tested was approximately $125,000, excluding the
umbilical line, installation, and training.
_Original signed by Gregory A. Mack    2/16/07         Original signed by Sally Gutierrez	4/4/07
Gregory A. Mack                           Date       Sally Gutierrez                            Date
Vice President                                         Director
Energy, Transportation, and Environment Division       National Risk Management Research Laboratory
Battelle                                                Office of Research and Development
                                                       U.S. Environmental Protection Agency
     NOTICE: ETV verifications are based on an evaluation of technology performance under specific,
     predetermined criteria and the appropriate quality assurance procedures. EPA and Battelle make no expressed or
     implied warranties as to the performance of the technology and do not certify that a technology will always
     operate as verified. The end user is solely responsible for complying with any and all applicable federal, state,
     and local requirements. Mention of commercial product names does not imply endorsement.

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