Errors associated with particulate matter measurements on rural sources: appropriate basis for regulating cotton gins

Agricultural operations across the United States are encountering difficulties complying with current air pollution regulations for particulate matter (PM). PM is currently regulated in terms of particle diameters less than or equal to a nominal 10 μm (PM10); however, current legislation is underway to regulate PM with diameters less than or equal to a nominal 2.5 μm (PM2.5). The goals of this research were to determine the biases and uncertainties associated with current PM10 and PM2.5 sampling methods and to determine the extent to which these errors may impact the determination of cotton gin emission factors. Ideally, PM samplers would produce an accurate measure of the pollutant indicator; for instance, a PM10 sampler would produce an accurate measure of PM less than or equal to 10 μm. However, samplers are not perfect and errors are introduced because of the established tolerances associated with sampler performance characteristics and the interaction of particle size and sampler performance characteristics. Results of this research indicated that a source emitting PM characterized by a mass median diameter (MMD) of 20 μm and a geometric standard deviation (GSD) of 1.5 could be forced to comply with a 3.2 and 14 times more stringent regulation of PM10 and PM2.5, respectively, than a source emitting PM characterized by a MMD of 10 μm and a GSD of 1.5. These estimates are based on both sources emitting the same concentrations of true PM or concentrations corresponding to the particle diameters less than the size of interest. Various methods were used to estimate the true PM10 and PM2.5 emission factors associated with cotton gin exhausts and the extent to which the sampler errors impacted the PM regulation. Results from this research indicated that current cotton gin emission factors could be over-estimated by about 40%. This over-estimation is a consequence of the relatively large PM associated with cotton gin exhausts. These PM sampling errors are contributing to the misappropriation of source emissions in State Implementation Plans, essentially forcing Air Pollution Regulatory Agencies to require additional controls on sources that may be incorrectly classified has high emitters