L –
LEGISLATIVE DISCUSSION
The three main purposes of a
fallout dust monitoring programme are:
1.
To meet
legislative requirements.
2.
To
indicate long term trends.
3.
To
generate or maintain awareness of dust generating activities on site.
The method and equipment used should assist in achieving these purposes.
The National Environmental
Management: Air Quality Act, 2004 (Act No. 39 of 2004) (NEMA) contains a
schedule called the National Dust Control Regulations and the latest draft
version of this document specifies the use of the ASTM D1739 method. The
definition of dust is also given as particles that have a diameter smaller than
100 micrometers.
The definition of dust also excludes the small particles of carbonaceous matter
directly emitted by a combustion process. This definition implies that some
sort of quantification in the sample of the carbonaceous matter will be
required.
The schedule makes for clear allocation of the residential action level to
residential and light commercial areas and by inference applies the industrial
action level to all other land areas which would include heavy industrial areas,
farmlands, and any other land not classified as residential or light commercial
as per the local town planning scheme.
The schedule also requires that the fallout dust at the boundary or beyond the
boundary, of the premises from where the dust originates, not be above 600_mg/m2/day
for residential and light commercial areas and not be above 1200_mg/m2/day
for all other areas.
This implies that the dust collected in the bucket has to be identified as
coming from a particular source and that the limit only applies to the dust
coming from that particular source.
The single bucket unit will collect dust from all dust sources in the area and
if the limit has to be applied to dust from a particular source then a
directional fallout dust monitoring method is required. The four bucket
DustWatch unit was designed specifically to meet this requirement. This is
discussed in more detail below, but this is why we apply the limits specified to
each individual bucket of the four bucket DustWatch unit.
The SANS 1929:2005 document specifies in section 4.8.6 that the reference method
for dustfall is ASTM D1739 and includes a note saying that “Any other method
which can be demonstrated to give equivalent results may be used.” This
document also specifies that modelling techniques can be used to supplement
measurement techniques. If the results are below the lower assessment threshold
(presumably 300_mg/m2/day)
then modelling can be used without actual measurements, although initial actual
measurements will probably be required.
The SANS 1929:2005 document also specifies that the dustfall sampling points
should be placed within a maximum distance of 2km of the boundary of the
source. Monitoring units placed within the boundary of the source are not
subject to the dust deposition criteria in 4.8.2.
The ASTM D1739 98(2010) method is the latest version of this standard. This
standard defines the dust that is collected as material smaller than 1mm. This
method does not require water to be added to the buckets before being placed in
the field, although an earlier version of this standard ASTM D1739 82 did
require water to be added. The 98 version of the standard also requires the
buckets to be twice as high as the diameter of the bucket.
The ASTM D1739 98(2010) standard specifies that this method is crude and
non-specific, and useful in the study of long term trends. These comments need
to be kept in mind when operating a fallout dust monitoring programme.
The United States of America does not have any
air quality standards for particulate matter larger than a d50 of 10 micron (PM10).3
The progress in the technology of fallout dust monitoring continues to move
forward in countries where fallout dust monitoring is included in their
environmental legislation. Australia, the UK and South Africa are among the
countries that have fallout dust monitoring in their environmental legislation
with application action levels.
The wind shield design described in the ASTM
98(2010) standard is a shield that surrounds the bucket and prevents wind from
blowing directly over the lip of the bucket. The shield provides a sheltered
area for the bucket to stand in and also allows for dust that enters this
sheltered area to land around the bucket and not be collected in the bucket.
Only dust that settles into the actual bucket is collected, the dust that
settles within the shield but outside the diameter of the bucket is not
collected. This design needs to be considered when comparing it to the wind
shield design of the Dust Watch unit.
The windshield design of the DustWatch unit was born out of experience by Gerry
Kuhn in the mining industry and working with fan designs used to move dust-laden
air from one area to another. To prevent dust from wearing the edge of the fan
blades away, the shape of the blades had to be designed to limit the dust
particles from hitting the blade. The design of the DustWatch wind shield acts
in a similar way and redirects the wind blowing towards the lip of the bucket up
and over the bucket. In addition to the physical change in the direction of the
air and dust, a low pressure above the bucket is created and as a result the air
from below the bucket moves upward around the end of the bucket and further acts
to prevent the collection of the dust during windy conditions.
The DustWatch wind shield design causes the fallout dust to be predominantly
collected under low wind and still conditions. The wind shield also provides a
particle size selection cut-off at a d90 of 100 Micron. The size cut-off can
vary if a localised dust source contaminates the sample and this is clearly
noticeable if particle size analysis is done. The four graphs below show
particle size distributions collected from the four-bucket DustWatch unit.
Individual buckets were used and the dust collected over a full year combined
for the analysis. The fourth graph shows the clear contamination by a localised
dust source that caused particles larger than 100micron to be collected in a
significant proportion. The other three graphs show the normal expected
particle size distributions from DustWatch samples.




The ASTM D1739 98(2010) does not mention the particle sizes collected in the
fallout dust monitoring other than the particles are less then 1mm. Many people
have ignored the PM10 fractions of the fallout dust that can be
collected and the long-term trends that can be provided and studied.
The wind shield design of the DustWatch unit therefore provides the same type of
shielding as the shield design described in the ASTM 98(2010) standard, but also
provides size selection and the collection of PM10 particulate. The
PM10 fraction of the fallout dust collected is shown in the graphs
above. The use of water in the bucket throughout the monitoring period also
provides retention for small PM10 and PM2.5 particles and
this is also discussed in more detail below
The DustWatch is designed to meet the requirements of ASTM D1739 but this does
not cater for wind direction so we have retained the fundamentals of the
standard within the design of the four bucket DustWatch unit.
With the origins of monitoring having been established with the American
Standard Test method (ASTM 1739D) there have been several developments in the
field and improvements to the original open bucket collection methodology.
An article by G Kornelius and M Kwata compares certain aspects of the 82 and 98
versions of the ASTM D1739 standard. This article compared the fallout dust
collection with a wind shield and without a wind shield as well as the fallout
dust collection with water added and not added to the buckets at the start of
the monitoring period. The wind shield was shown to increase the collection and
retention of dust with in the bucket, although additional statistical analysis
was recommended. The addition of water to the buckets at the start of the
monitoring period (all samples with a wind shield) was also tested and
statistically analysed using linear correlation and forcing the regression line
through the origin. The article concluded that there was some evidence to
indicate that adding water at the start of the monitoring programme would
increase dust retention, but the statistics used did not show significance.
Additional statistics might have revealed some significance.
Based on the article by G Kornelius and M Kwata and the fact that the previous
version of the ASTM standard included the addition of water to the bucket at the
start of the monitoring programme, we have chosen to always add water to the
buckets at the start of the monitoring programme.
Other factors that should be considered here are that rain falls into the
bucket, so there may be water in the bucket anyway. If one considers the
potential disturbance of the dust in a dry bucket when a raindrop hits the
bottom of the bucket, the value of having water in the bucket is obvious.
When dust is collected in a bucket
then it settles quite quickly depending on the particle size over an estimated
time of 30 minutes, after which all the particles will have settled to the
bottom of the bucket except the very fine particles.
We assume that the requirement in the ASTM 98(2010) standard to have a bucket
that is twice as high as the diameter is meant to keep the dust that lands in
the bucket from escaping from the bucket. As the bucket may have no water in
it, this is an important requirement, but we suspect that the height would have
to be significantly more than twice the diameter to achieve total capture of all
dust particulate.
The design of the selector disk emulates the operation of an aircraft wing; a
feature working at wind velocities exceeding 3.0 m/s. The feature results in
diversion of any particulate larger than 0.5mm that is wind driven at 3.0 m/s or
more over the selector opening. This feature also minimise the capture of grits
while the wind is blowing. The collected dust and particulate thus only occurs
when the wind velocity falls to a point where precipitation is possible. Under
extremely quiet conditions the very fine dust fractions are precipitated as
well.
The collection height has been
selected with several features in mind. The lifting of +500µm material in a 3.0
m/s wind velocity can only in a rare aerodynamic form achieve a height of about
2.0 m. The bucket lips are positioned at 2.2m.
The buckets can be reached for ease
of handling by persons of 1.5m or taller. The elevating support cradle locks in
position, protecting the buckets from theft or pilfering to a degree.
The selector disk runs on a 318
stainless steel shaft running in a nylon or Vesconite bushing for a longer
trouble-free life with a minimum possibility of binding and maintenance. The
disc is also dynamically balanced to minimise rotation bias.
We regularly consider and evaluate the methodology of the fallout dust
monitoring programme and the equipment used to collect the samples.
We are often asked to comment on
how the directionality of the four bucket DustWatch unit works and offer the
following arguments. When the wind stops blowing from a certain
direction then the atmosphere above the unit will contain dust that came from
that direction (the direction the wind was blowing from). So for the period
with no wind the dust collected will still ideally be from the source in the
direction that the wind was blowing from.
If the wind quickly changes direction, rotates
the lid and then stops, then depending on how long it blew from the new
direction, there will be some cross contamination of fallout dust from the two
directions in the buckets.
There is also the complication of different wind
directions at different levels in the atmosphere and other wind patterns that
bring dust from one direction and deposit it from another direction.
In line with the “crude and non-specific, and useful
in the study of long term trends” statement in the ASTM standard, the above
complications with regard to wind patterns and the operation of the DustWatch
lid to open different buckets under different wind conditions seem reasonable
for the value of determining directional fallout dust emanating from a
particular source.
The colour of the dust on the filters and the Microscan differences noted
between filters taken during the same cycle from a four bucket dust watch unit
are good indicators of the DustWatch units capability to determine directional
fallout dust.
Legislative Table
Highlighting Key Issues
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ASTM 1982
Method
|
ASTM 1998
Method
|
Single Bucket DustWatch
Method
|
Four Bucket DustWatch
Method
|
|
No Wind Shield |
|
Includes Wind Shield to prevent wind from
blowing over the lip of the bucket. |
Includes Wind Shield to prevent wind from
blowing over the lips of the buckets. |
|
|
|
|
|
|
|
No Water Used in Bucket |
Water Used in the Bucket. |
Water Used in the Buckets. |
|
|
|
|
|
|
Unit of Measure
g/m2/day |
Unit of Measure
g/m2/day |
Unit of Measure
mg/m2/day |
Unit of Measure
mg/m2/day |
|
|
|
|
|
|
Particle Size Collected – Estimated to be
above 10 micron and smaller than 1000
micron |
Particle Size Collected – Estimated to be
above 10 micron and smaller than 1000
micron |
Particle Size Collected – Estimated to be
above 1 micron and smaller than 100 micron |
Particle Size Collected – Estimated to be
above 1 micron and smaller than 100 micron |
|
|
|
|
|
|
Sampling Period – 30 days ± 3 days |
Sampling Period – 30 days ± 3 days |
Sampling Period – 14 days ± 3 days or 30 days
± 3 days provided that water can be kept in the bucket over the full
sampling period. |
Sampling Period – 14 days ± 3 days or 30 days
± 3 days provided that water can be kept in the buckets over the full
sampling period. |
|
|
|
|
|
|
Does not collect PM10 and PM2.5
Particulate |
Does not collect PM10 and PM2.5
Particulate |
Collects PM10 and PM2.5
particulate as it lands in the bucket. |
Collects PM10 and PM2.5
particulate as it lands in the buckets. |
|
|
|
|
|
|
Temperature of air in bucket maintained due
to water in bucket. Turbulence is minimised within the bucket. |
Temperature of air in bucket varies with
ambient air temperatures, day and night. |
Temperature of air in bucket maintained due
to water in bucket. Turbulence is minimised within the bucket. |
Temperature of air in buckets maintained due
to water in buckets. Turbulence is minimised within the buckets. |
|
|
|
|
|
|
No ability to provide long-term trends of
where the dust originated in areas with multiple industries that generate
dust. |
No ability to provide long-term trends of
where the dust originated in areas with multiple industries that generate
dust. |
No ability to provide long-term trends of
where the dust originated in areas with multiple industries that generate
dust. |
Can provide long-term trends of dust
originating from different directions in areas with multiple industries that
generate dust. |
|
|
|
|
|
|
South African Limits applicable if using this
method. Residential action level of 600_mg/m2/day
or industrial action level of 1200_mg/m2/day. |
South African Limits applicable if using this
method. Residential action level of 600_mg/m2/day
or industrial action level of 1200_mg/m2/day. |
South African Limits applicable if using this
method. Residential action level of 600_mg/m2/day
or industrial action level of 1200_mg/m2/day. |
South African Limits applicable if using this
method. Residential action level of 600_mg/m2/day
or industrial action level of 1200_mg/m2/day
applied to each bucket as the buckets ideally collect dust from where it
originated. |
|
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|
|
|
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Height of Bucket to Diameter not specified |
Height of bucket specified to be twice the
diameter of the bucket |
Height of Bucket not twice the diameter.
Water in the bucket compensates for this and improves collection of small
dust particles. |
Height of Bucket not twice the diameter.
Water in the bucket compensates for this and improves collection of small
dust particles. |
|
|
|
|
|
|
This method is crude and
non-specific, and is useful in the study of long-term trends. |
This method is crude and
non-specific, and is useful in the study of long-term trends. |
This method is crude and
non-specific, and is useful in the study of long-term trends. |
This method is crude and
non-specific, and is useful in the study of long-term trends. |
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Standard is not the latest version but still
in general use in South Africa |
Standard is the latest version and also used
in South Africa. |
Based on the latest ASTM standard and also
used in South Africa and Africa |
Based on the latest ASTM standard and also
used in South Africa and Africa |
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