I. Title Page Title: Evaluation of Prescribed Burn Impacts on Air Quality and Visibility in the Lake Tahoe Basin Subtheme this proposal is responding to Theme: Air Quality Subtheme: Assessing the impacts of fire on air quality Principal Investigator and Receiving Institution L.-W. Antony Chen, Ph.D. Division of Atmospheric Sciences Desert Research Institute 2215 Raggio Parkway Reno, NV 89512 Phone: 775-674-7028 Fax: 775-674-7009 Email: antony@dri.edu Mark C. Green, Ph.D. Division of Atmospheric Sciences Desert Research Institute 2215 Raggio Parkway Reno, NV 89512 Phone: 775-674-7118 Fax: 775-674-7009 Email: Mark.Green@dri.edu Co-Principal Investigator Agency Collaborator Grants Contact Person Funding requested: Total cost share (value of financial and in-kind contributions): Xiaoliaong Wang, Ph.D. Division of Atmospheric Sciences Desert Research Institute 2215 Raggio Parkway Reno, NV 89512 Phone: 775-674-7177 Fax: 775-674-7009 Email: xiaoliang.wang@dri.edu N/A Lycia Ronchetti Business Manager Division of Atmospheric Sciences Desert Research Institute 2215 Raggio Parkway Reno, NV 89512 Phone: 775-673-7411 Fax: Email: Lycia.Ronchetti@dri.edu $190,100 $47,715 0 II. Proposal Narrative a. Project Abstract Prescribed burning that is widely used for fuel reduction in the Tahoe basin potentially impact air and water quality, visibility, and human exposure of air toxics. A thorough evaluation of this impact has not been achieved due to lack of field measurements for pile-/under-burn emissions and spatiotemporal distribution of smoke plumes. This project will employ a unique combination of source and ambient monitoring systems and satellite remote sensing data to address the knowledge gap. Source measurements will yield emission factors of criteria pollutants including particulate matter (PM) and ozone (O3) precursors, as well as particle size distribution, chemical composition, and light absorption coefficient. Ambient PM10/PM2.5 measurements will be made at five sites representative of community exposure in the basin. The prescribed burning impact on air quality/visibility will be linked to burn and meteorological parameters leading to recommendations for future burning strategies (e.g., burn window, season, location [in- and out- side the basin], and technique). The project will also establish a procedure to evaluate air quality through satellite data on a routine, cost effective basis. b. Justification Statement Lake Tahoe is a unique environmental asset that has been designated an “Outstanding National Water Resource” by the US Environmental Protection Agency (U.S. EPA) to protect its water quality and its scenic characteristics. An increasing concern to resource management agencies in the basin is the suspended PM and O3 that impact air quality and visibility. Biomass burning could be an important source of PM and O3 precursors, as Kuhns et al. (2004) attributed ~33% of the PM10 (particles with aerodynamic diameter ≤ 10 μm) mass emissions in the Tahoe Basin to wild and managed forest fires. PM2.5 and O3 precursors (i.e., carbon monoxide [CO], nitric oxide [NO], and volatile organic compounds [VOCs]) are pollutants subject to regulation by the National Ambient Air Quality Standards (NAAQS) and the 1999 Regional Haze Rule (RHR). Particles from biomass burning are enriched with black carbon (BC), which is mostly produced in combustion flames (i.e., dark smoke from a fire) (Chen et al., 2006; 2007). If deposited into lake water, BC can attenuate light 10 – 20 times more efficiently than dust particles, thus having significant impact on water clarity. In addition, Carignan et al. (2000) noted that fires release mobile ions such as soluble potassium (K+), chlorine (Cl–), phosphate (PO43-), sulfate (SO42–), ammonium (NH4+), and nitrate (NO3–). Nitrogen (N) and phosphorus (P), in both organic and inorganic compounds, are the most important nutrients affecting algal growth in the lake (Goldman et al., 1993; Goldman et al., 1993). Murphy and Knopp (2000) reported that atmospheric deposition accounts for approximately 55% of N and 27% of P load into Lake Tahoe. Prescribed burns have been used as one means to control fuel loads in Lake Tahoe forests, but the environmental impact of these burns has not been thoroughly evaluated. This project responds to the Air Quality Subtheme 3b: Assessing the impacts of fire on air quality, particularly focusing on the local and regional impacts of pile- and under-burns on ambient PM2.5 (particles with aerodynamic diameter ≤ 2.5 μm) level, chemical composition, O3 precursor concentration, visibility, and potential for deposition. This project will assess the role of meteorology and burn technique on fire impact zone through measurement, dispersion modeling, and data analysis. Results from this project are expected to contribute to best management practices (BMPs) for mitigating the environmental impact of prescribed burning. c. Background and Problem Statement More than 100 years of wildland fire suppression has altered ecosystems that evolved with fire and has led to a large buildup of biomass fuels. Land managers would like to reduce fuel loads through prescribed and, in some cases, natural burns as well as through other vegetation and ecological management methods. Prescribed burning reduces the surface fuels using understory and/or pile burning. Underburning is the application of surface fire below an overstory of large trees and is used to restore forest health and to mimic the historic process of low-intensity fire. Pile burning is used for fuel 1 reduction in areas not suitable for underburns. For safety considerations near residential areas, slash pile burning is usually the best treatment method following thinning treatments in overly dense stands that would burn too intensely in an underburn causing unacceptable levels of tree scorch and mortality. In the Lake Tahoe Basin prescribed burning is carried out under strict guidelines that follow a prescription from the Lake Tahoe Basin Management Unit (LTBMU) and other agencies such as the Lake Tahoe Fire Protection Districts. Since 1997, thousands acres of landscape understory burns and prescribed pile burning have been implemented on the LTBMU. Most burns were carried out in spring and fall when numerous weather and other parameters are met. The prescribed burn areas in FY09– FY10, for example, included four counties (Douglas, Eldorado, Placer, and Washoe) surrounding the lake and were located in county, state, and national forest lands (Figure 1a). Many of the past and future prescribed burns are adjacent to residential/commercial areas in Incline Village, NV, Stateline, NV, South Lake Tahoe, CA, and Tahoe City, CA. The smoke plumes are often observable and smellable, and are most likely adverse to visibility and human health. I V IV II III (a) (b) Figure 1. Maps of (a) LTBMU fuels treatment status and (b) MODIS satellite Lake Tahoe fire event. The five circles in (a) indicate five population zones where ambient monitoring will be carried out as part of this study to assess community exposure. The satellite image was acquired on 6/25/2007 during Angora fire. White meshes in (b) indicate GOES satellite grid for AOD measurement (4 km 4 km). Understanding the spatial and temporal distribution of pollutants released from prescribed burning is a critical aspect to evaluate the impact of burning. This has not been achieved due to lack of a comprehensive air monitoring network in the Tahoe basin. Efforts have been made to predict smoke 2 transport using integrated numerical models such as the CANSAC/BlueSky Smoke Forecast Model (Brown et al., 2003; McKenzie et al., 2006; Larkin et al., 2009). However, earlier evaluations of the BlueSky model (e.g., Adkins et al., 2003 and Berg et al. 2003) for the Hayman and Rex Creek wildfire indicated that the BlueSky predicted PM2.5 concentrations were significantly lower than the measured data. One of major uncertainties was attributed to PM2.5 emission factors. Emission factors could change rapidly over the course of a burn (Chen et al., 2007; 2010), and time-integrated emission factors are not adequate for air quality modeling (though they are more useful for developing emission inventories). It is also not trivial to model plume rise accurately in complex terrain. Satellite imaginary has been recommended and used to complement ground-based reporting for fire location, timing, and scale. Smoke plumes can be resolved well by satellite, as exemplified by Figure 1b for a wildfire event. The Moderate Resolution Imaging Spectroradiometer (MODIS) onboard polar orbiting satellites Terra and Aqua provides twice daily observations at a spatial resolution of ~1 km 1 km. Plume concentrations, however, can change substantially between satellite overpasses while temporal interpolation may lead to large uncertainties. Geostationary satellites such as Geostationary Operational Environmental Satellites (GOES) provide better temporal coverage (down to 30 min between two snapshots). Although GOES spatial resolution is relatively coarse (e.g., 4 km 4 km), Figure 1b shows that this resolution may still be adequate for determining the extent of smoke impact in the Tahoe basin. The aerosol optical depth (AOD) reported by MODIS or GOES represents column-integrated PM loading, which often correlates reasonably with surface PM10/PM2.5 concentrations during pollution episodes (e.g., Green et al., 2009). The regression slopes, however, are event-specific. The AODPM10/PM2.5 relationship for Tahoe burning events needs to be established if satellite data are to be used to infer burning impacts on air quality. Prescribed burning in the Lake Tahoe Basin will continue. It is one important tool for the Forest Service to effectively reduce the threat from wildfire and manage the forest areas for a more fire resistant condition. Efforts need to be made, however, to reduce the impact of smoke resulting from prescribed burning on air and water quality in the basin. This includes two aspects: 1) to understand the emission and transport of particles/gases from prescribed burning as a function of burn type and weather conditions; and 2) to establish satellite remote sensing as a complementary tool for monitoring regional air quality and visibility on a routine, cost effective manner. These tasks will require conducting an intensive monitoring program for selected prescribed burns in the Tahoe basin. d. Goals, Objectives, and Hypotheses This proposed research seeks to improve our understanding of the contribution of prescribed fires to air pollutant levels in the basin. The goal will be realized by meeting the following research objectives: 1) Survey burn type (e.g., pile or understory), fuel loading and conditions (moisture content, carbon and nitrogen content), and weather pattern for each of the selected burn events. 2) Apply a comprehensive source monitoring system to characterize particle and gas emission/ambient concentration/particle size distribution in plumes immediately downwind of the burn events. 3) Assess burn pollutant transport through secondary monitoring sites representative of community exposure in the basin. 4) Establish and verify procedures for satellite remote sensing of regional air quality/visibility as a tool for assessing prescribed burning impacts. One major hypothesis of this study is that smoke plumes from a confined burn area can influence a broad downwind region through turbulent mixing within the atmospheric boundary layer (ABL). Pile burns could affect air quality more than understory burns due to more intensive fires causing greater emission rates and totals. For the same reason, burning in fall when fuel moisture is lower would show greater impacts. It is also hypothesized that incremental PM2.5 concentration can serve as a 3 surrogate/indicator for prescribed burning impact on air quality. e. Approach, Methodology and Location of Research The experimental approach is designed according to the research objectives: Task 1: Survey burn and weather parameters for each of the selected burn events The field studies will investigate impacts of both pile and understory burning. We will work with personnel from LTBMU and other agencies to select burn events in fall 2011 through summer 2012. We have been working with the Forest Service for a SNPLMA Round 7 project: “Potential Nutrient Emissions From Prescribed Fire in the Lake Tahoe Basin” (Chen et al., 2010). Effort will be made to study burns both inside and outside the basin since they have different transport patterns. Based on forest ecology of the Tahoe basin our choice for measurement should cover four major fuel types: 1) manzanitadominated; 2) sagebrush-dominated; 3) grass- and herbaceous species-dominated; 4) pine needle litterdominated. It is expected that 5 – 10 individual burn events will be investigated. Field survey conducted prior to each burn will include fuel type, load, and moisture content. Fuel loading in particular burn plots will be estimated by line transect sampling (McRae et al., 1979; Taylor and Fonda, 1990) or photo series methods (Reeves 1988; Ottmar et al., 2000). Moisture content of fuel will be determined by measuring the mass loss after holding the fuel sample at 90 ºC overnight. Fuel C and N content will be determined by a FlashEA1112 CHNS-O analyzer (Thermo Scientific Inc., MA, USA) at DRI. Meteorological data covering the entire burn event (from 24 hrs before the burn to 24 hrs after the burn) will be acquired through the Western Regional Climate Center (www.wrcc.dri.edu) and archived for data analysis. Weather forecasting will be used to locate the source monitoring system. Task 2: Quantify particle/gas emission factors, plume concentration, and particle size distribution A DRI “In-plume” monitoring system will be located immediately (5 – 100 m) downwind of the burn plot to 1) characterize pollutants emitted as a function of time and 2) determine burn pollutant concentrations relative to PM2.5. Temporally-resolved emission factors will be useful for modeling pollution transport over the basin. On the other hand, concentrations of any pollutant further downwind may be estimated from PM2.5 concentration if the ratio of the pollutant to PM2.5 does not change. Figure 2 illustrates the In-plume system (Wang et al., 2010). It draws air from biomass burning plumes, dilutes it with filtered air, and quantifies carbon dioxide (CO2), CO, NO, nitrogen dioxide (NO2), sulfur dioxide (SO2), total volatile organic compounds (VOCs), size-resolved PM including PM10 and PM2.5, BC, and visibility (through light extinction coefficient) on a continuous basis with time resolutions of 1 – 6 seconds. Particle size information is particularly useful for determining the potential for deposition. Time-integrated samples by filters will be acquired for laboratory analyses of PM2.5 and selected hydrocarbon (HC). PM2.5 speciation includes mass, elements (Na to U), water-soluble ions (K+, PO43-, SO42–, NH4+, NO3–, etc.), organic carbon (OC), elemental carbon (EC), and air toxics such as polycyclic aromatic hydrocarbons (PAHs). The In-plume system is modularized and packaged into five pelican boxes, and is transportable by a small pickup truck. The entire system is powered by two 12 Volt (V) deep cycle marine batteries (EnerSys Energy Products Inc., Reading, PA, USA). From the In-plume measurements, fuel-based emission factors can be derived using a carbon balance approach (Andreae and Merlet, 2001): EFx [ x] FC biomass ([CCO2 ] [CCO ] [CHC ] [CPM ]) (1) where FCbiomass is the carbon fraction in the biomass, and [C]CO2, [C]CO, etc. are the carbon concentrations of various species in the smoke (background subtracted), and [x] is the concentration of species x (also 4 background subtracted) of interest in the smoke. The EFs are expressed in terms of mass of pollutant emitted per unit mass of fuel burned. If multiplied by the biomass density (kg biomass burned/acre of burned area) the fuel-based emission factor of Eq. (1) can be transformed into an activity-based emission factor (kg pollutant emitted/hectare of burn). To allow the science team from DRI to participate in field measurements during prescribed burn events all personnel will take the US Forest Service’s Basic 32 Fire course (J. Washington, Fuels Battalion Chief, Fire & Aviation Management, Lake Tahoe Basin Management Unit, pers. comm., 2007). Sample Inlet 1 L/min DustTrak (PM10) 1 L/min 5 L/min DustTrak (PM2.5) 1.2 L/min 0.7 L/min 0.05 L/min 3 L/min 2.08 L/min 5 L/min 5 L/min 5 L/min 0.01 L/min 1 L/min 0.5 L/min 0.16 L/min Diluted Background 0.5 L/min PP Systems CO2 sensors Undiluted 0.5 L/min 5 L/min MiniVol Figure 2. Schematic diagrams of the In-plume monitoring system and ambient monitoring suite (upperright corner). The listed In-plume flow rates are for operation with a dilution ratio of 40. The dilution ratio can be adjusted according to smoke concentrations. Task 3. Assess burn pollutant transport and community exposure in the Tahoe basin Five mobile monitoring suites (Figure 2, upper-right corner) will be installed at five sites representative of community exposure: 1) Incline Village, NV, 2) Round Hill/Kingsbury/Stateline, NV, 3) South Lake Tahoe, CA, 4) Tahoma or west shore, CA, and 5) Tahoe City, CA (see Figure 1a) to assess transport of pollutants from prescribed burning. Siting within each community will follow Chow et al. (2002) considering sufficient operating space, access and security, and environmental control. A survey of each community zone will be conducted in early 2011 to determine exact site location. This survey is leveraged by an ongoing Round 10 project: “Visibility Monitoring and Standards for Lake Tahoe Basin: Assessment of Current and Alternative Approaches” (PI: Antony Chen), which is tasked to design a visibility monitoring network for Lake Tahoe. Twenty-four hours prior to a targeted burn event, the mobile monitoring suites will be brought to the sampling sites and activated. Each suite consists of paired TSI DustTraks to measure PM10 and/or PM2.5 in real time and a battery-powered MiniVol sampler (Airmetrics Inc., San Leandro, CA, USA) equipped 5 with quartz-fiber filters to collect integrated particle samples (Figure 2). An inertial impactor will be used to remove particles greater than 2.5 m aerodynamic diameter from the MiniVol sample flow prior to PM sample collection. The filter samples will be submitted to DRI laboratories for analysis of particle mass, nutrient species, OC and EC, and BC (through light absorption coefficient). The impact of prescribed burning on PM10/PM2.5 concentrations will be assessed by analyzing time series of DustTrak measurements. The plume arrival time at each site is first estimated by the NOAA Hybrid Single Particle Lagrangian Integrated Trajectory Model (http://ready.arl.noaa.gov/HYSPLIT.php). The HYSPLIT dispersion mode with North American Mesoscale Forcast System (NAM) meteorological data will be employed. It is acknowledged that use of HYSPLIT with the 12 km resolution of the NAM meteorological fields provides only an approximation of actual plume transport speed and direction. We will also use surface meteorological data (e.g. the National Weather Service [NWS] South Lake Tahoe monitoring station) to validate plume transport direction. PM10 and PM2.5 levels prior to the plume arrival time are considered as a primary baseline for calculating the incremental PM10/PM2.5 concentration caused by prescribed burning. In addition, Watson and Chow (2001) demonstrated a successive moving average subtraction method that can distinguish neighborhood versus regional contributions. Mass measured from filters will verify PM2.5 concentrations measured by DustTrak. Biomass burning markers (e.g., EC, K+, and PM2.5/PM10 ratio) will further verify prescribed burning contributions to PM2.5 at the sampling site. Although other pollutants are not measured at these community sites, their concentration increases due to burn events may be estimated from the incremental PM2.5 concentration and ratio of PM2.5 to these pollutants determined by In-plume system near the burn. This should apply to CO, NO, BC and other primary pollutants that have long enough atmospheric lifetimes (i.e., > 1 day) against deposition and chemical reaction. In one day, most of the pollutants would be vented out the basin. To verify this hypothesis, additional CO and NO analyzers will measure at one of the five sites usually the site closest to the burn area side-by-side with the mobile monitoring suite. Visibility (in terms of light extinction coefficient) is often correlated well with PM2.5 concentration (Chow et al., 2006). A nephelometer can also be installed at this one site to evaluate the degree to which visibility can be inferred from PM2.5 measurement. Task 4. Establish and verify procedures for satellite remote sensing of air quality Continuous PM measurements at the community sites provide evidence of potential burning impacts on human exposure and visibility. The impacts will be linked to various burn and meteorological parameters. Satellite data can assess the spatiotemporal distribution in greater detail (e.g., Figure 1b), so satellite data will also be included in the data analysis. GOES Aerosol/Smoke Product (GASP) AOD covering each of the burn events will be obtained from the NOAA Center for Satellite Applications and Research (STAR). Quality assurance of the satellite data have been performed by NOAA, including an opaque cloud product to indicate block-out zones due to solar reflectance, clouds, extreme view angles, saturation, vegetation type, and other factors. MODIS AOD has been shown to be of higher accuracy than GOES AOD, but the data is typically available at only near 11:30 am and 1:30 pm local time. We will compare MODIS AOD and GOES AOD and evaluate both against surface PM2.5 and PM10 data. The GOES imagery at 30-min resolution will first be used to verify the HYSPLIT dispersion model confirming the smoke plume arrival times. AOD calculated from GASP represents an average column aerosol loading in a 4 km 4 km cell. Through the Kriging interpolation technique, AOD at the six monitoring sites (one In-plume and five community) will be calculated and closely compared with surface PM2.5 measurement. Analysis at Fresno, California has shown that the PM2.5/AOD relationship is sensitive to ABL mixing depth and that by accounting for mixing depth, improved PM2.5/AOD relationships can be obtained. We will use HYSPLIT mixing depths computed from NAM meteorological model output to define the PM2.5/AOD relationship. It is also noted that an elevated smoke plume can give high AOD with low surface PM2.5 concentrations. We can use the satellite and surface measurements to assess whether the smoke plumes are reaching the surface. 6 The regression slopes of AOD versus PM2.5 for burn and non-burn periods and different PM2.5 loading ranges will be determined. PM2.5 concentration over the entire Tahoe basin can therefore be mapped out based on AOD measurements. These regression slopes will be tested for their consistency across various burn events. This will provide an evaluation of their applicability to future prescribed burn and/or wildfire activities. Since the satellite data is accessible to the public at no cost, this approach could be proven valuable as a complementary PM and visibility measurement on a routine basis. f. Relationship of the Research to Previous and Current Studies SNPLMA funded a Round 7 project to study potential nutrient emission and deposition from prescribed burning. Emission factors of air pollutants were found to be sensitive to fuel type and moisture content (Chen et al., 2010). However, that study was based on >100 laboratory burn experiments. This proposed project focuses on measuring actual burns, providing a validation to the previous results (and emission inventories stemmed from them). The project also complements several PM and visibility source apportionment studies conducted for Lake Tahoe, including Tahoe Source Characterization Study (TSCS, see Kuhns et al., 2004) and three Round 10 projects (PI: D. Obrist, M. Green, and A. Chen). g. Strategy for Engaging with Managers The DRI research team will coordinate with LTBMU for field measurement of prescribed burn emissions, and work closely with the Tahoe Regional Planning Agency (TRPA) to select community monitoring sites. The conclusion of the project will lead to strategies to mitigate prescribed burning impacts. In order to ensure effective use of the data obtained as part of this study the results will be communicated to key constituents working to improve air and water quality in the basin, particularly TRPA. Ongoing progress and results will be presented to the Tahoe Science Consortium (TSC), EPA Region 9, TRPA, CARB, Lahontan, NDEP, UC Davis, UNR, Caltrans, and NDOT. Our assessments will be presented at the biannual Tahoe Science Symposium to maximize communication and information dissemination. Scientific publications in peer-reviewed journals will result from this project. h. Deliverables and Products A transportable, battery-powered In-plume monitoring system specifically adapted for measurement of emissions from prescribed burning, and five mobile ambient monitoring suites for quantifying community exposure. These systems and their measurement methods will be described in peerreviewed literature and at conferences enabling other researchers to benefit from our experiences made during the proposed project. Such systems can be used to study wildfire impacts as well. Emission factors for major prescribed burning activities under ambient conditions determined with a well-documented system and measurement procedures. Provide assessments for the impact of prescribed burning on regional air quality and visibility and recommend strategies (e.g., burn season, location, technique, and weather conditions) for mitigating the smoke impact. A well-tested procedure to evaluate air quality through satellite remote sensing data. The research results of this project will be transitioned to stakeholders including land management agencies, state air quality agencies, regional planning organizations and others involved in state implementation plan (SIP) formulation. The draft final report will contain all measurement results, data analysis, conclusions, and recommendations. Comments and suggestions on the draft report will be incorporated into the final report, which will be delivered 3 month after the project period. Progress will be tracked through regular e-mails and conference calls with the program manager(s). Research results will also be made available through the internet. 7 Schedule of Milestones The project is expected to be completed in 18 months (6/1/2011 – 12/31/2012). Milestone/Deliverables Prepare progress reports Source and ambient monitoring system Field study – fall burns Field study – Spring burns Start Date End Date Description 6/1/2011 12/31/2012 Submit brief progress report to Tahoe Science Program coordinator by the 1st of July, October, January, and April. Prepare summary of annual accomplishments in January. 6/1/2011 8/30/2011 Configure In-plume system and mobile sampling suites. Begin study design and sampling plan 9/1/2011 10/31/2011 Carry out field survey and prescribed burn measurements for fall burning events 3/1/2012 6/30/2012 Carry out field survey and prescribed burn measurements for spring burning events Laboratory analysis for PM and biomass fuel samples Integrated Data Analysis 11/1/2011 7/30/2012 Analyze fuel and PM chemical composition and other properties 12/1/2011 Draft Report 10/1/2012 9/30/2012 Analyze data for emission factors, pollutant transport assessment, and remote sensing method development 12/31/2012 Complete draft report. Draft report submitted to TSC by 12/31/2012 Final Report 12/31/2012 3/31/2013 Complete revisions to final report and prepare associated manuscript(s) for submission to peer-review journal 8 References Adkins, J.W.; O’Neill, S.M.; Rorig, M.; Ferguson, S.A.; Berg, C.M.; Hoadley, J.L. (2003). Assessing accuracy of the BlueSky modeling framework during wildfire events. 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On-board Emission Measurement from the World's Largest Heavy Haulers. In Proceedings, Leapfrogging Opportunities for Air Quality Improvement, Chow, J. C., Watson, J. G., Cao, J. J., Eds.; Air & Waste Management Association: Pittsburgh, PA, 476. Watson, J.G.; Chow, J.C. (2001). Estimating middle-, neighborhood-, and urban-scale contributions to elemental carbon in Mexico City with a rapid response aethalometer. J. Air Waste Manage. Assoc., 51(11): 1522-1528. 10