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EPRI's "Lesson Learned" Website

To access EPRI's "Lessons Learned" Website, click on the EPRI logo below to login.  Once you have logged in, select the "EPRI Collaboration" tab at the top right of the screen.  Then select "Continuous Mercury Monitoring Forum" in the Community Projects box on the left hand side of the screen.  This site is available for EPRI members only.

EPRI Home

Hg Calibrator Activity

Last Updated on 10/19/07 – See Below

10/19/07

Update on Hg Elemental Calibrator NIST Certification 

Our last update on the status of NIST Traceability of elemental Hg calibrators and EPA Traceability Protocols was on 8/21/07 or approximately two months ago.  Input was requested from the involved parties was requested several days ago and is quoted below.  In the cases where no response was received, that has been indicated and I have substituted the best information I have based on other sources.

EPA 

"EPA intends to temporarily waive the NIST-traceability requirement for elemental and oxidized Hg calibration gas standards until January 1, 2010.   The planned waiver will only apply to the NIST-traceability requirement for the Hg calibration gas standards.  It does not defer the CAMR requirement for Hg monitoring systems to be installed and certified by January 1, 2009.  Please note that this planned waiver is subject to change and will not become official until our proposed Part 75 rule modification package is final.  We expect the rule package will be signed and published within the next few months.

EPA plans to phase in the NIST traceability requirement for Hg calibration gas standards during the waiver period.  In the first phase (2008), EPA will invite stakeholders, including, among others, Hg monitoring equipment vendors, cylinder gas suppliers, key NIST personnel, and representatives from industry to participate in a demonstration program, the purpose of which will be to collect the data that EPA needs to finalize the NIST traceability protocols.  Two key elements of the demonstration program will be: (1) assessment of the field performance of elemental and oxidized Hg generators; and (2) evaluation of the long-term stability of elemental Hg compressed gas cylinders.  Based on the results of the demonstration program, EPA intends to finalize the elemental and oxidized Hg traceability protocols and issue them by December 31, 2008.

During the second phase (2009), the affected sources will be required to implement the final protocols, to ensure that their generators and cylinders are certified as NIST-traceable before the waiver period expires.  Beginning on January 1, 2010, full NIST traceability is required for all Hg calibration gas standards used in the CAMR program.  Only those Hg gas generators and cylinders that meet the requirements of the final traceability protocols will be considered NIST-traceable.

EPA is currently revising the August interim traceability protocol for elemental mercury gas generators, taking into account comments received from industry. We plan to incorporate major components of the revised interim protocol into a draft work plan for implementing the field demonstration program.  EPA then plans to hold a meeting/conference call with key stakeholders in November to review the draft work plan and begin developing the field demonstration program." 

NIST

No written update was received from NIST.  I understand that two bottled gas vendors have sent cylinders to NIST for evaluation (see below updates).  NIST is presently working with those bottles and initially observed concentration drift during gas extraction.  One bottle was rolled to thoroughly mix it and the drift problem disappeared.  Tests have not been done on the remaining bottles. 

Thermo

“Thermo has received two certified vendor prime calibrators from NIST.  These vendor primes cannot be used because no certification reports have been received from NIST.  Thermo received and responded to an inquiry Email from EPA regarding calibrator test procedures.  Thermo suggested a relaxed transfer protocol as an interim procedure so that user calibrators were related to the vendor primes.” 

Tekran

“Tekran has received two certified vendor prime calibrators from NIST.  These vendor primes cannot be used because no certification reports have been received from NIST.  Tekran met with NIST and EPA.  Tekran also supports a relaxed transfer protocol as an interim procedure.” 

Hovacal

“The HovaCAL is now available in a fully automated version.  The HovaCAL Quick AC can be integrated into an Hg CEMS for daily, weekly or monthly calibration.” 

Spectra Gases

“The Spectra Hg NTRM prime cylinders are at NIST and we are waiting for their results.” 

Air Gas

“Airgas has six elemental mercury cylinders at NIST in a wide range of concentrations.  They have been analyzed for two months now and we have been advised by NIST that they are very stable.” 

RMB

As noted in the last update (see below), EPA transmitted draft elemental Hg calibrator Traceability Protocols to “selected” individuals on 08/14/07.  RMB prepared comments on the Protocols and sent them to EPA.  Basically, the Protocols could not be implemented in a practical manner.  Therefore, as noted in EPA’s update above, the requirement for NIST-traceability has been postponed until January 1, 2010 and the Protocols will be revised to reflect field performance of the calibrators during calendar year 2008.  RMB is presently working on a draft test plan outline for the field demonstration program discussed in EPA’s comments above.  The outline will include tasks, responsible parties, deliverables and schedule for each task.  In order to accomplish the objectives of the demonstration program, I need a number of utility companies to participate in the data gathering portion of the project.  We need a cross section of both Thermo and Tekran users.  If you are interested, please give me a call (919-510-0483) and we can discuss the details.  There will be some manpower commitment necessary but it will serve as excellent training.

08/21/07

Update on Hg Elemental Calibrator NIST Certification

It has been three weeks since our last update on the status of NIST Traceability of elemental Hg calibrators and EPA Traceability Protocols. I apologize for the long delay between updates but other project activity and considerable travel has interfered. I have also received a complaint from one of the interested parties concerning the posting of opinion in our last update. If you are not interested in my opinion, you are welcome to stop reading now.

Input received from various interested parties for this update is quoted below.

EPA

“On August 14, EPA completed an Interim Traceability Protocol for Elemental Mercury Gas Generators and submitted it to generator manufacturers and protocol collaborators for feedback prior to its full implementation. The purpose of this interim traceability protocol is to provide procedures for manufacturers or their designees (a) to qualify representative samples of elemental mercury gas generators, (b) to certify individual elemental mercury gas generators, and (c) to conduct quality control checks in the field. The interim protocol incorporates comments received on the previous May “working draft” traceability protocol. At a later date, user-friendly uncertainty calculation
spreadsheet(s) will also be incorporated into the protocol.

The interim protocol uses qualification and certification tests to establish traceability of field generators (user-primes) to NIST-certified generators (vendor-primes). The qualification tests have been designed to examine representative sample generators for potentially significant operating variables (e.g., back pressure, temperature and flow control, operating environment temperature and voltage, drift, etc) and their effect on candidate generator output performance. In turn, certification tests have been designed to establish a quantitative relationship between each candidate user-prime generator and the reference vendor-prime generator.

The interim traceability protocol also requires that field quality control (QC) checks be performed by the user or its designee on each certified elemental mercury (Hg) generator (i.e., user-prime) to insure that the traceability obtained during certification testing is maintained (i.e., to insure that the generator's output remains stable). The objective of the field QC checks is to show, to the greatest extent possible, that the user-prime did not change significantly between certification and use.

The initially certified user-prime generators must be recertified on an annual basis or if they fail to attain the acceptance criterion for the field QC check. The recertification may be performed at the facility of the manufacturer that previously certified the user-prime or in the field by the manufacturer or another service provider using a vendor-prime (of the same model as the user-prime) and the same certification procedure.

A memorandum accompanies the interim traceability protocol which summarizes the important points in the protocol and also includes a waiver or deferral period until January 1, 2009 in which certain procedures and acceptance criteria specified in the protocol will be relaxed. This waiver or deferral period allows sufficient time for generator performance data to be collected and analyzed to verify that the acceptance criteria outlined in the protocol are achievable and/or for manufacturers to modify the generators to attain the criteria. EPA plans to review these data as they become available during Calendar Year 2008 and make necessary adjustments/modifications as necessary to this interim traceability protocol prior to January 1, 2009. We believe this waiver or deferral period is reasonable because mercury monitoring data reported to EPA in 2009 will not be used in the trading of allowances, as allowance accounting under the Clean Air Mercury Rule (CAMR) does not begin until 2010.

The acceptance criteria provided in the interim traceability protocol and accompanying memorandum do not take into account that fact that humidification of the Hg generation stream may be required in many applications in order for Hg CEMS to pass required daily calibration and weekly system integrity tests. Humidification will alter the certified concentration output of the user prime generator as well as increase its overall combined uncertainty. We will evaluate the effect of humidification during the waiver period (until January 1, 2009), and if appropriate, may add uncertainty acceptance criteria for generator gas stream humidification to the traceability protocol.”

NIST

“The elemental mercury work at NIST is continuing. The work on four elemental mercury generators, two for each of two manufacturers, has been completed. Specific set points on these generators have been certified. Reports are in process and the generators are being shipped to the manufacturers as Vendor Primes. We are starting work on three mercury mixtures in compressed gas cylinders. We continue to work with Western Research Institute to better understand the performance of the generators.”

Thermo

“Thermo is awaiting return of the certified vendor prime calibrators and certification reports from NIST.”

Tekran

“Tekran is awaiting return of the certified vendor prime calibrators and certification reports from NIST.”

Hovacal

“The HovaCAL digital MF (same as HovaCAL Quick with internal flow metering) was certified by TUV Rheinland, Germany for the components Mercury Chloride, Elemental Mercury, Water, Hydrogen Chloride, Hydrogen Fluoride and Ammonia. The requirements are derived from the European Guideline DIN EN 14 181. The TUV report is available in German or English language at info@hovacal.de”

Spectra Gases

“Spectra will be shipping Hg NTRM Prime cylinders to NIST by the end of the month.”

RMB

As you may recall from our last update (see below), NIST was having precision and accuracy problems with the first series of calibrator comparison tests. One of the Hg CEMS vendors dispatched an engineer to NIST to evaluate the situation. It was discovered that NIST had not plumbed the calibrators properly and had created a back pressure situation that was influencing the results. Obviously, the traceability tests had to be redone.

As noted in the EPA update above, EPA transmitted draft Traceability Protocols to “selected” individuals on 08/14/07. However, EPA requested that the Protocols not be circulated. I have asked EPA to release those Protocols for broad distribution within the utility and stack testing industry so that the protocol requirements can be used for planning purposes.

We will put the protocols on this web site if and when EPA releases them.

08/01/07

Update on Hg Elemental Calibrator NIST Certification

I would like to update you on the latest news on the elemental Hg Vendor Prime calibrator certifications at NIST. This update is based on information received from NIST, EPA and the calibrator vendors over the past week.

There has been some difficulty at NIST performing the Vendor Prime certifications. According to NIST the vendor calibrators have exhibited poor accuracy and precision. As of last Thursday, NIST had looked at four calibrators and the reproducibility (precision) ranged from 0.3 to 3%. The accuracy was not very good and the slopes of the calibration curves varied. In our opinion, reproducibility as high as 3% is virtually impossible considering the repeatability of the mass flow meters in the calibrators is 0.015%. In addition, some of the discussion concerning reproducibility and accuracy does not match our field experience at all. We have found the calibrators to be very reproducible and several different vendor’s calibrators have been cross compared with very good results. So the bottom line is we believe that something is wrong with the experimental setup and/or operation of the calibrators. To top it off, it turns out that EPA had given NIST a 1% acceptance criteria for reproducibility. While this specification may be desirable in a perfect world, it is “over the top” relative to our ability to make Hg measurements in power plant stacks.

Therefore, NIST indicated that they could only certify one of the four calibrators. However, considering all the difficulty and variable data were not comfortable with that certification. We certainly agree that the problem has to be solved before “certified” calibrators are sent out the door. The bottom line is that no calibrators will be sent back to the vendors until NIST has the opportunity to discuss the situation with the vendors and discuss options with EPA.

EPA is still working on traceability protocols and claims that they will have “working protocols” done by the first week in August. We will see if that really happens because that is over a month later than originally promised and I would not be surprised to see further slippage.

07/11/07

RMB - In response to a progress update request from RMB to Hg calibrator vendors, EPA, NIST and WRI, the below information was received. I only expected an update from EPA, NIST and WRI since “the ball has been in their court” for the past month. WRI did not provide an update. Thermo and Airgas did provided updates so they are also included.

I am trying hard to be polite so I will only say that I am extremely disappointed in the glacial rate of progress on this project. Just to remind everyone, today is the two month anniversary of our departure from Phoenix and as of today there are no vendor prime generators and there are no protocols. And every week that passes puts another 20 calibrators in the field. This game gets uglier with every flip of the calendar.

EPA - Here is our update on generator certification procedures / traceability protocols for July 10:

1) We have developed a draft approach for direct "nose-to-nose" comparison for certifying generators, including those already in the field and a draft approach for performing field QC checks for field Hg generators.

2) An update to the working draft elemental mercury gas generator protocol has been prepared incorporating these approaches and is now being reviewed internally. We are planning to provide the next working draft in approximately 1 to 2 weeks once the internal review has been completed.

3) We are continuing to develop uncertainty equations and spreadsheets for the elemental Hg generators. The focus of these equations are to provide uncertainty estimates for both the direct nose to nose comparison "error propagation" approach and the original regression analysis approach to certifying generators.

4) We are continuing our collaborations with NIST and vendors to resolve the remaining issues regarding procedures to certify NIST prime, vendor prime and user prime generators (including both elemental and oxidized generators). As we understand it, NIST has completed the necessary NIST prime measurements and are now preparing to conduct the vendor prime measurements.

NIST - The NIST Prime Generator is certified and will be used to begin the certification process on two Vendor Primes on Monday July 16, 2007.

Airgas - NIST now has a set of Airgas mercury calibration gases for verification.

Thermo - Thermo is waiting for an update from NIST on the 4 elemental calibrators in NIST possession. NIST has indicated that the calibrators would be certified in July.

Thermo had delivered a PO for NIST certification of the above units on 6/18/07. After Thermo receives the 3 Vendor Prime units, additional units will be shipped to NIST. Thermo believes that up to 5 additional Vendor Prime units may be required depending upon how field certification is ultimately defined by the EPA.

Thermo has provided NIST with multiple (6-8) Hg concentration points that are required to have units certified on ranges from 10 to 40 microgram/m3.

Thermo has shipped +30 HgCl2 generators, primarily as part of an upgrade program currently in place. The generator shipments will accelerate as we move forward into the 2nd half of 2007, and as first field testing is completed.

06/18/07

In response to a progress update request from RMB to Hg calibrator vendors, EPA, NIST and WRI, the following information was received.

EPA – The following information was received from EPA for this update.

1. We are continuing to work through an approach for direct "nose-to-nose" comparison for certifying currently uncertified generators already in the field and to modify/further develop field QC procedures for Hg generators. We are tentatively planning to provide these procedures in an update to the working draft in approximately 2 to 3 weeks.  

2. We are also continuing to develop uncertainty equations and spreadsheets for the Hg generators. The focus of these equations are to provide uncertainty estimates for both the direct nose to nose comparison "error propagation" approach and the original regression analysis approach to certifying generators. The spreadsheets are calibration equations which yield predicted reference standard readings for specific candidate generator settings and the extended uncertainty .  

3. We continue to work with Western Research Institute as they begin to implement their generator variability/uncertainty testing.  

4. We have received feedback on the working draft traceability protocol from vendors and RMB and are incorporating their comments as appropriate.  

5. We are continuing our collaborations with NIST and vendors to resolve the remaining issues regarding procedures to certify NIST prime, vendor prime and user prime generators (including both elemental and oxidized generators). As part of these collaborations, we are working closely with several vendors to aid them in understanding what the traceability protocol inherently requires, and work with them to develop practical approaches.

NIST – In response to my suggestion that consultants, integrators and testing companies may desire to obtain Vendor Prime calibrators, I received the following communication from NIST.

Anyone wishing to have an elemental mercury generator certified at NIST as a Vendor Prime must contact NIST in advance to negotiate terms and timing.  Timing is important since NIST wants to minimize turn around time and a backlog of generators at our facility will increase this time.  Currently the cost of certification is $10,000 per one unit or $15,000 per two units.  

Contact information

Bill Dorko
NIST
100 Bureau Drive, Stop 8393
Gaithersburg, MD 20899-8393

william.dorko@nist.gov

voice   301-975-3916
FAX    301-977-8392

RMB – RMB transmitted a draft Field Calibrator Validation Protocol and Periodic QA/QC Protocol to EPA on 6/04/07. On 06/06/07 RMB received a call from EPA explaining that a different (more complicated) approach was needed to satisfy the “expanded uncertainty” mathematics. RMB anticipates no further activity until EPA has some words on paper to review.

Western Research Institute – No additional information was received from Western Research for this update.

Airgas – Airgas is submitting to NIST 6 mercury calibration gas standards within the month. Airgas is being very optimistic to believe that we will get results back sometime this fall according to NIST.

Ducon – As previously reported, Ducon has sent two elemental calibrators to NIST for certification as Vendor Primes. Ducon is developing an automated calibration system with an oxidized mercury calibrator using the Hovaquick.

Hovacal – Hovacal sent a note stating that they had no new information for this update. It should be noted that the Hovaquick is the oxidized Hg calibrator being used by EPA and RMB in the Hg CEMS development studies.

Opsis – No response was received or expected since Opsis does not supply head space calibrators.

PSA - PSA is still concerned about the technical correctness of the ICMPS approach used by NIST and potential conflicts with other International Standards. PSA referenced me to an ASTM method (D6350) for measuring Hg in natural gas as an example of a potential conflict. I have not had the opportunity to review this ASTM Method. PSA is working on an oxidized Hg calibrator.

Spectra – Spectra is in the process of producing the NTRM prime cylinders for shipment to NIST. NTRMs spend a relatively long time "in house" before they are shipped to NIST for their analyses and naming.

Tekran – Tekran prepared three reference calibrators and shipped two of them to NIST for certification as Vendor Prime calibrators. The third calibrator will be retained by Tekran to evaluate the returned calibrators for shipping damage. The calibrators were shipped to NIST on 6/13/07. Included in the shipment was a very nice spreadsheet on the calibration points and a computer programmed to automate the process. Tekran has an oxidized Hg calibrator in production. No results have been publicly reported.

Thermo – Below is a slightly edited version of the response received from Thermo.  

Thermo has provided 4 calibrators to NIST, the first was to be the NIST Prime, the 3 that arrived end of May were designated as Vendor Primes.  

NIST has acknowledged receipt of these units, but has only done a visual inspection to date. They indicated receipt in good condition with no sign of damage. NIST indicated that they would go through "acceptance" tests this week (whatever that means), but they will not be certified until July.  

NIST also has asked for the following which Thermo is in the midst of completing:  

1) A written statement saying that Thermo is sending in x units with the identifying serial numbers (why NIST needs this since they have the units, we don't know).

2) A written statement from Thermo saying why we sent them (ie, to be certified as Vendor Primes). NIST has emails to this regard already.

3) A written statement describing the output levels that Thermo wants certified or a statement saying that it is the NIST option as to what levels to certify.  

Item 3 requires discussion with EPA and we have a phone conference this afternoon to finalize.  

NIST is also asking $15K per two units for their services which appears very high. Nevertheless, Thermo has given them a PO # to proceed.  

As far as the oxidizer is concerned, multiple units are in customer hands. All that are installed and operating are achieving between 70% - 90% oxidation, with recovery efficiencies ranging from 80's to 98%+. We are finding that (1) each site has its own issues/difficulties and (2) some adjustment of flows, as well as 24 - 48 hours of conditioning, improves performance. Thermo has also been modifying software to allow easier automation of the oxidizer module. We are making significant progress as more units are out there, but until all operate as required by regulation, we still have work to do.

Sick – No response was received or expected since Sick does not supply head space calibrators.

As an observation, I will note that we have been involved in a number of conversations recently concerning Hg CEMS certifications and testing schedules. Unfortunately, the way the rule is presently constructed, no Hg CEMS can be certified until it is equipped with a NIST traceable elemental and oxidized calibrator. Perhaps EPA plans to fix the rule in the upcoming rulemaking. I certainly hope so.

05/31/07

In response to a progress update request from RMB to Hg calibrator vendors, EPA, NIST and WRI, the following information was received.

EPA – "The Agency very much welcomes RMB's initiative to track progress on this issue since it may provide for a means to effectively expedite the development of procedures to certify vendor prime and user prime (candidate field) generators and in completing the necessary mercury traceability protocol documents.  We agree that this issue needs to be managed with a sense of urgency and as such we welcome the opportunity to communicate with the wider monitoring community, including EPRI, utilities, vendors, CEMS users and others, our progress updates on these traceability issues."

"The following is our progress update on generator certification procedures / traceability protocols subsequent to the May CEMS User's Group conference:

  1. We are continuing to work on a second revised version of the working draft elemental mercury gas generator protocol provided on May 3, 2007

  2. As a top priority for this revised working draft, we are working through an approach for direct "nose-to-nose" comparison for certifying currently uncertified generators already in the field. This is an option to the linear regression and interpolation technique specified in the working draft. We are tentatively planning to provide the next working draft in approximately 3 to 4 weeks that will include this direct nose-to-nose comparison approach. The revised working draft will also include field QC check procedures and uncertainty equations.

  3. EPA ORD's contractor has prepared the first draft uncertainty spreadsheet using statistical linear regression analyses as stated in the protocol (the spreadsheet is as calibration equation which yields predicted reference standard readings for specific candidate generator settings and the extended uncertainty) - although this specifically applies to the linear regression approach, portions of the spreadsheet that have application to our direct nose-to-nose error propagation comparison approach we're working on.

  4. We have received a test plan outline from Western Research Institute that provides a conceptual design for testing the uncertainties associated with the mercury gas generators. We have provided feedback to WRI for them to use in finalizing their test plan.

  5. We are receiving feedback on the working draft from vendors and have received comments from RMB.  (We would like to thank RMB for its comments on our working-draft elemental mercury gas generator traceability protocol.)  We are assessing these comments and will incorporate them as appropriate in the next version of the working draft protocol.

Again thank you for your efforts to expedite this important effort."

NIST – "Mercury work at NIST, in support of implementing CAMR, is continuing along two lines, elemental and oxidized mercury."

"Technical representatives from NIST and EPA had a meeting with the Tekran technical people at the Tekran facility on May 29-30 to try to make progress on resolving the bias between elemental and oxidized calibration standards."

"At this meeting there was also discussion and some decision on the specific mercury generator output concentrations to be certified at NIST."

"The two laboratories at NIST that are involved in the mercury work are currently operational.  The "3rd floor" lab, where the ICP-MS primary method work is done, and the "1st floor" lab, where the comparative work is done."

"We have a generator that will be quantified as the NIST Prime."

"We are accepting mercury generators from manufacturers to be certified as Vendor Primes.  The NIST Prime generator, which is quantified by ICP-MS, will not be finished until July 1.  There was conflicting program scheduling for the one analytical unit that is used in this procedure.  However, the Protocol and Technical Procedure documents for this primary method have been in place for over a year and were submitted to EPA in 2006.  This procedure has been employed to quantify five specific mercury generators in 2006."

"Candidate Vendor Primes that are delivered will be put through acceptance testing.  This can be done without a NIST Prime since we have a generator available that is characterized well enough to be used for comparative purposes to determine whether or not candidate Vendor Primes are functioning well enough to actually put through the certification process which is time consuming.  We will not start the certification process, and waste a lot of time, on a candidate generator if it is not functioning correctly."

"We are working with WRI to provide them with an equivalent of a Vendor Prime and also working with them to examine the effects of shipping on generator performance."

RMB – RMB has provided comments to EPA and NIST on the Draft Traceability Protocol for Qualification and Certification of Elemental Mercury Gas Generators.  A draft Field Calibrator Validation Protocol and Periodic QA/QC Protocol are in preparation and will be transmitted in the next few days.  Yes – I am behind schedule on that transmittal.

Western Research Institute - WRI has sent an elemental Hg calibrator to NIST for certification as a vendor prime.  WRI is also setting up to conduct pressure and temperature stability tests.  Receipt of an environmental chamber needed for these experiments is scheduled for the week of 06/04/07.

Ducon – Two calibrators have been sent to Western Research.  Comments on the draft Traceability Protocol are in preparation.

Hovacal – An oxidized mercury calibrator (HovaCAL Digital 111-MF) was shipped to NIST on 03/06/06.  Start up and training was conducted on 03/15/06.  Hovacal has received no feedback on the status of the NIST evaluation.

Opsis – No response was received or expected since Opsis does not supply head space calibrators.

PSA - PSA is still negotiating terms with NIST, discussing how many calibrators would need to be certified and what costs are involved.  Pending resolution, PSA has not yet sent an elemental Hg generator to NIST for the purpose of obtaining a certified Vendor Prime calibrator.  PSA is still reviewing the EPA/NIST Draft Traceability Protocol for Qualification and Certification of Elemental Mercury Gas Generators.  Comments should be finalized by 06/04/07.  PSA uses an in house certification procedure which utilizes NIST certified components. PSA will continue to use this approach until it is satisfied with the technicalities of the EPA Traceability Protocol and NIST certification procedure.

Tekran – Tekran has sent EPA and NIST comments on the draft Traceability Protocol.  Tekran is preparing three reference calibrators and will ship two of them to NIST for certification as Vendor Prime calibrators.  The third calibrator will be retained by Tekran to evaluate the returned calibrators for shipping damage.  The scheduled shipping date is the first week of June.

Thermo – Thermo has sent EPA and NIST comments on the draft Traceability Protocol.  Thermo had previously sent a calibrator to be certified as a NIST Prime.  This calibrator was received by NIST on 05/01/07.  Three more calibrators were sent to NIST on 05/29/07 to be certified as Vendor Prime calibrators.

Sick – No response was received or expected since Sick does not supply head space calibrators.

As an observation, I will call your attention to the one month slippage (to July 1) in the NIST schedule to prepare the NIST Prime calibrators.  As a practical matter, and in the absence of further delay, this means that Vendor Prime calibrators will not likely be in the hands of the vendors before August 1.  My closing comment is that general weekly updates will likely be overkill (and a hell of a lot of work for everyone) so expect future updates about every two weeks.  In the event that specific important activities occur, they will be posted as needed between updates.

05-14-07

This web page has been developed as a follow up to Richard McRanie’s presentation on May 10, 2007 at the EPRI CEM Users Group meeting.  It is for the purpose of tracking EPA and NIST progress on delivering Vendor Prime elemental Hg calibrators and appropriate protocols.  We will also track Hg monitor vendor progress in shipping calibrators to NIST and implementing the NIST protocols into the manufacturing process.  It is RMB’s plan to update this web page on a periodic basis.  Trimble County project supporters will receive a direct update by E-mail several days prior to the web page update

As a reminder, NIST has committed to a 30-day turnaround of Vendor Prime calibrators from the date a calibrator is received from the vendor.  EPA has also committed to a protocol development schedule that will not delay Vendor Prime transfer to User Prime implementation.

The following schedule is suggested as an accountability marker:

  • NOW – Vendor shipment of calibrators to NIST

  • 30-Days - NIST shipment of Vendor Primes back to vendors

  • 30-Days - EPA finalizes Vendor Prime to User Prime transfer protocol

  • 60-Days – EPA finalizes User Prime field certification transfer protocol

The action items above are critical path.  There are additional items that need to be accomplished with respect to Hg calibrator traceability.  Below is a complete list for elemental calibrators and you will note that the first three items are scheduled above while the last three items have not been scheduled.  It is our plan to add the last three to the schedule list after further discussions with EPA and NIST.  We should also note that no action items have been scheduled for the oxidized Hg calibrators.

Action items for elemental Hg calibrators:

  • Prepare NIST to Vendor Prime transfer protocol (NIST)

  • Prepare Vendor Prime to User Prime transfer protocol (EPA)

  • Prepare User Prime field certification transfer protocol (EPA)

  • Prepare User Prime periodic QA/QC procedure (EPA)

  • Prepare Vendor Prime recertification protocol (NIST/EPA ?)

  • Prepare User Prime recertification protocol (EPA?)

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