Aerosol Science and Technology

ISSN: 0278-6826 (Print) 1521-7388 (Online) Journal homepage: https://www.tandfonline.com/loi/uast20

The Ddevelopment and Designation Testing of a

New USEPA-Approved Fine Particle Inlet: A Study
of the USEPA Designation Process

L. C. Kenny, T. Merrifield, D. Mark, R. Gussman & A. Thorpe

To cite this article: L. C. Kenny, T. Merrifield, D. Mark, R. Gussman & A. Thorpe (2004) The
Ddevelopment and Designation Testing of a New USEPA-Approved Fine Particle Inlet: A
Study of the USEPA Designation Process, Aerosol Science and Technology, 38:S2, 15-22, DOI:
10.1080/027868290502290

To link to this article: https://doi.org/10.1080/027868290502290

Published online: 17 Aug 2010.

Submit your article to this journal

Article views: 1527

View related articles

Citing articles: 13 View citing articles

Full Terms & Conditions of access and use can be found at

https://www.tandfonline.com/action/journalInformation?journalCode=uast20
Aerosol Science and Technology, 38(S2):15–22, 2004
Copyright
c American Association for Aerosol Research
ISSN: 0278-6826 print / 1521-7388 online
DOI: 10.1080/027868290502290
The Development and Designation Testing of a New
USEPA-Approved Fine Particle Inlet: A Study of the USEPA
Designation Process
L. C. Kenny,1 T. Merrifield,2 D. Mark,1 R. Gussman,2 and A. Thorpe1
1
Health and Safety Laboratory, Sheffield, UK
2
BGI Inc., Waltham, Massachusetts
This article discusses the practical challenge of meeting USEPA
requirements for equivalency between novel particulate matter
monitoring instruments and the USEPA WINS PM2.5 Impactor
(i.e., the Federal Reference Method sampler for fine particulate
matter). A project was undertaken to develop a new PM2.5 instru-
ment in which the WINS impactor was substituted by a cyclone, to
give superior performance over long sampling periods under heavy
loading. Empirical cyclone models were used to develop a new gen-
eration of very sharp cut cyclones (VSCC), together with a par-
ticular VSCC specimen suited to PM2.5 sampling at 16.67 l min−1 .
In laboratory tests, this VSCC demonstrated a precise 2.5 µm D50
cutpoint and sharpness as good as the WINS. A formal applica-
tion was then undertaken to achieve USEPA Class II Equivalency
designation. The process included aerosol laboratory loading tri-
als, with results showing no change in cutpoint after up to 90 days
between cleaning cycles. Field trials to compare the VSCC to the
WINS FRM were then performed in both western and eastern air
sheds to demonstrate the precision and accuracy of the candidate
VSCC FEM. The results showed that the VSCC instrument yielded
precision and accuracy within USEPA requirements, although the
USEPA data requirements for the field trials (in terms of aerosol
size distribution and concentration) were not fully met. The out-
come of the project was that the Class II equivalency designation
was achieved, but not without major difficulties in gathering suit-
able and sufficient data to meet the stringent test requirements laid
down by USEPA. Some changes in the designation procedure are
recommended in light of this experience.
Received 19 June 2003; accepted 11 June 2004.
We thank the State of Connecticut Department of Environmental
Protection for cooperation and use of their Windsor, CT sampling sta-
tion, the State of Arizona Department of Environmental Quality for
cooperation and use of their laboratory and Phoenix, AZ Super Site,
the USEPA and Contractor Research Triangle Institute, and the EPA
Technical Review Committee.
Address correspondence to Lee C. Kenny, Health and Safety Lab-
oratory, Broad Lane, Sheffield S7 1LB, UK. E-mail: Lee.kenny@
hsl.gov.uk
INTRODUCTION
Methods for measuring ambient concentrations of particulate
matter (PM) may be designated as Federal Reference Methods
(FRM) or Federal Equivalent Methods (FEM) in accordance
with the Code of Federal Regulations (40 CFR Part 53). A list
of designated reference and equivalent methods is updated pe-
riodically and is available from the USEPA (Federal Register
2002).
Reference methods for fine particulate matter (PM2.5 ) were
first designated in 1998. The PM2.5 FRM samplers utilize an
impactor, the Well Impactor Ninety Six (WINS), as a fractiona-
tor to select PM2.5 downstream from a wind-tunnel-proven inlet
(Tolocka et al. 2001) operating at a flow rate of 16.67 l min−1 .
This inlet’s performance was well characterized during the de-
velopment of an earlier generation of sampling instruments for
PM10 , and this eliminated the need for all but confirmatory wind
tunnel testing of the new generation of PM2.5 samplers. FRM
samplers collect a single sample of PM2.5 onto a filter for gravi-
metric analysis. Three classes of equivalent methods are envis-
aged; Class I equivalent samplers utilize the same inlet and size
fractionator as the FRM method but are adapted to collect se-
quential filter samples of PM2.5 ; Class II equivalent samplers
can utilize an inlet and/or size fractionator of different design to
the FRM but collect a single sample onto a filter for gravimetric
analysis; and Class III equivalent samplers are any devices not
falling into either Classes I or II. For example, instruments that
collect and analyze PM continuously rather than producing filter
samples for analysis would fall into Class III.
The stated purpose of allowing equivalent methods is to en-
courage the development of improvements to reference methods;
however, all candidate equivalent method samplers are required
to undergo rigorous testing and meet exacting performance re-
quirements in order to be designated, as detailed in the Federal
Register (1997). There are generic laboratory tests of perfor-
mance that apply to all three Classes of FEM, as well as ad-
ditional specific tests that are required for Class II and Class
15
16 L. C. KENNY ET AL.
III equivalent samplers, depending on the nature of the design
deviations from the FRM inlet and fractionator systems. In the
case of inlet deviations, full wind tunnel testing of the alternative
inlet would be required. In the case of fractionator deviations,
the alternative fractionator is required to be tested in terms of
its particle size separation and loading characteristics. Finally,
in addition to these laboratory performance tests, field tests are
required for all three classes of FEM samplers to demonstrate
precision and accuracy in comparison with colocated FRM sam-
plers. For Class II and Class III samplers, these field tests must
take place in two different air sheds, possessing specified charac-
teristics in terms of particle size distribution and concentration in
order to highlight any biases attributable to the design deviations
in the fractionator system.
Given the technical challenges and costs involved in under-
going the required testing programs for equivalency, there has
been almost no progress in developing and designating FEM
samplers since 1998. Several instrument manufacturers have de-
veloped prototype sequential samplers (Class I FEM) but none
have yet been formally submitted for designation. The first and
only designated Class II FEM for PM2.5 was approved in 2002
and is described in this article. Many of the state authorities
responsible for regular monitoring of PM2.5 against national
ambient air quality standards would prefer, for practical rea-
sons, to use Class III equivalent automatic PM2.5 samplers as
alternatives to the FRM. Unfortunately, although several com-
mercially available instruments exist, the requirements for PM2.5
Class III equivalent method designation (for automated meth-
ods) are considered technically impossible and cost prohibitive,
and therefore no commercial instrument company has pursued
this endeavor to date.
It is interesting to note that since 1982, when the first am-
bient particulate reference method for TSP was designated, all
reference and equivalent USEPA methods since approved re-
main designated regardless of any subsequently reported data
and operational faults. Rules for performance and data accep-
tance are included in 40 CFR Part 53; however, the USEPA has
never challenged or removed a method for poor performance,
once it is designated. Field and performance data for several of
the previously designated reference methods have demonstrated
poor precision and accuracy, and some have a failure rate not
acceptable for state and local agency use. Additionally, there
is a growing list of designated methods that are obsolete and
no longer commercially available but that remain as published
USEPA methods.
Given the extremely demanding requirements for both PM2.5
Class II and III equivalency, the instrument we describe in this
article is the first and only approved equivalent method (FEM)
to be designated since promulgation of the USEPA fine parti-
cle method in 1997. This sampler uses a very sharp cut cyclone
(VSCC) as the PM2.5 fractionator in place of the WINS impactor
but is otherwise identical to an FRM sampler. An earlier project
to develop an alternative fractionator to the WINS impactor
was undertaken as a collaboration between BGI Instruments
(BGI), Rupprecht & Patashnick Company, and the UK Health
and Safety Laboratory (HSL) in 1996 through 1999 (Kenny et al.
2000). The resulting sharp-cut cyclone (SCC) was submitted for
verification by the USEPA and its contractor, who found it to
exhibit small sampling biases with respect to the USEPA WINS
impactor (these data remain unpublished). For this reason, BGI
and HSL undertook a new project in 2001 to further improve the
SCC. The VSCC is the result of that work, and it is now a des-
ignated Class II equivalent method. As we show in this article,
achieving Class II equivalent method designation is a protracted
and technically challenging process. However, it is feasible, at
least if the design modifications to the FRM are limited to the
fractionator system.
DEVELOPMENT AND TESTING OF THE VSCC
Rationale
Based upon the published opinions of prominent epidemi-
ologists (Schwartz et al. 1996 ) regarding excess deaths from
sub-10 µm particles, in 1995 The American Lung Association
brought a suit against EPA and forced a review of the methods
existing at that time for ambient particulate sampling, which
were based on the sub-10 µm fraction of ambient aerosol, PM10
(Federal Register 1997). While there was complete agreement
that a size-selective median cutpoint lower than 10 µm was re-
quired for health-related particulate monitoring, there was no
consensus as to what it should be. Opinion ranged from 4 µm
down to 1 µm. In the absence of available hard scientific infor-
mation, PM2.5 was selected for historical reasons. To meet the re-
quirement for a secondary PM2.5 fractionator, USEPA staff con-
sidered both cyclone and impactor devices (Peters et al. 1996)
and, based upon laboratory testing, selected a well-type wetted
surface impactor (Peters et al. 2001a). This device was given
the appellation Well Impactor Ninety Six (WINS). It is impor-
tant to note that because of the court-imposed time schedule, no
definitive field trials were conducted prior to its introduction.
Part of the published FRM requirement was that the sec-
ondary PM2.5 fractionator should meet the following perfor-
mance requirements:
1. D50 cut to be 2.5 ± 0.2 µm.
2. Sampling bias for three predefined ambient particle size
distributions to be less than 5%.
Initial laboratory testing of the WINS indicated that it could
meet these criteria. After a few years of experience in the field,
two areas of concern with the WINS surfaced, in the form of
“frozen” WINS oil at low ambient temperatures and the effect
of loading on the cutpoint and bias. The USEPA studied both of
these problems and published their findings (Vanderpool et al.
2001a,b).
Independent experiences reported with the WINS stimulated
the development of a replacement device (Kenny et al. 2000).
The main drive for this work was the desire to develop continu-
ous monitors in order to reduce the personnel costs of
 VSCC DESIGN AND DESIGNATION
monitoring. The loading effects noted for the WINS indicated
that it would not be suitable for continuous monitoring in many
situations because the loading effects precluded extended oper-
ation between cleaning cycles. Cyclonic devices were demon-
strated to have significant advantages over impactors for ex-
tended operation; however, problems remained in eliminating
bias between the candidate cyclones and the WINS.
Design and Validation of the Penetration Curve
The very sharp cut cyclone is a tangential, round-entry cy-
clone based on the design of the SRI-II cyclone originally de-
scribed by Smith et al. (1979). The SRI cyclones were developed
for size-selective stack sampling but have since proved useful
for a range of applications stemming from a re-examination of
their characteristics by Kenny and Gussman (1997). This work
showed that cyclones could be dimensionally scaled using an
empirical “family model” peculiar to a given cyclone geome-
try. The family model relates cyclone cutpoint (i.e., penetration
D50 ) to cyclone body diameter and flow rate. For a given cyclone
geometry the family model has only two empirical parameters,
which means that the model can be fitted from minimal experi-
mental data, for example, D50 values measured at only two flow
rates for a single specimen of the cyclone family. Once the fam-
ily model is known, it can be used to calculate the dimensions
for other family members that will yield a specified D50 at a
specified flow rate.
Our work on the SRI cyclones led to the development of
three useful families of cyclones. The GK family, with similar
Figure 1. Schematic diagram of the VSCC cyclone, showing the principal dimensions.
17
geometry to the SRI IV cyclone, has a very gradual (i.e., un-
sharp) penetration curve ideally suited to occupational hygiene
sampling. The SCC family, with similar geometry to the SRI
III cyclone, has a much sharper penetration curve and offers
comparable size selectivity to the WINS impactor for ambient
PM2.5 sampling, but with much better performance under load-
ing (Kenny et al. 2000). Finally, the VSCC cyclone described in
this article is closely modeled on the SRI-II cyclone described
by Smith et al. (1979).
Early experience with the SRI cyclones demonstrated that
small differences in cyclone geometry sometimes have a large
impact on the sharpness of a cyclone’s penetration curve. This
was further explored in a systematic investigation of the effects
of geometrical modifications on cyclone penetration (Kenny and
Gussman 2000). The results from this work indicated how to
modify cyclone geometry in order to improve the sharpness of
cyclone selectors and suggested that the SRI-II cyclone should
have an extremely sharp penetration curve. This prediction was
confirmed by the results of tests carried out on the Andersen
AN3.68 cyclone (Peters et al. 2001b), which on investigation
proved to have almost identical geometry to the SRI-II. Utiliz-
ing all available data on the SRI-II and near clones, a “working”
family model for a new VSCC cyclone family was estimated.
The working model was used to calculate the dimensions for
a prototype VSCC cyclone expected to give a D50 cutpoint
close to 2.5 µm at a flow rate of 16.67 l min−1 . A schematic
diagram of the cyclone showing the dimensions is given in
Figure 1.
18 L. C. KENNY ET AL.
Our previous experience with pooling data from various
sources led us to expect that there would need to be minor
adjustments to the prototype design, in order to compensate
for uncertainty in our initial estimates of the “working” family
model parameters. Fortunately, the work on cyclone geometry
suggested a simple way to optimize the prototype. We had ob-
served a linear relationship between D50 and vortex finder length
(S in Figure 1), whereas vortex finder length did not significantly
change the sharpness of the penetration curve. This finding al-
lows the D50 of the penetration curve of a cyclone to be “tuned”
by a few tenths of a micrometer by adjusting the vortex finder
length (keeping all other parameters constant). The prototype
VSCC was made with two alternative tops, one with a short vor-
tex finder and one with a long one. The optimum vortex finder
length was deduced experimentally by linear interpolation of
the D50 data obtained with the different vortex finders (which
bracketed the desired value). The final VSCC design was then
constructed and calibrated at a flow rate of 16.67 l min−1 in the
normal way. Additional tests at several other flow rates were
carried out in order to confirm the final VSCC family model.
The experimental methods used throughout to test the cyclones
were similar to those described in detail by Maynard and Kenny
(1995). For each aerodynamic diameter range, the average parti-
cle number counted with the cyclone present was divided by the
average number counted without the cyclone present to deter-
mine the aerosol penetration for that diameter. The penetration
values were analyzed using the software package Tablecurve
(Jandel Scientific) in order to locate the D50 , D16 , and D84 di-
ameters by interpolation. The sharpness values were calculated
as

 12
D16
Sharpness = ,
D84
and least-squares fitting to the data was used to obtain the final
VSCC family model:
ln(D50 ) = a + b ln(Dc ) − (b − 1) ln(Q),
where D50 is the penetration cutpoint in micrometers, DC is the
cyclone body inside diameter in centimeters, Q is the flow rate in
liters per minute, and a and b are empirical constants determined
using nonlinear least squares regression. Best fit values for a and
b were a = 1.415 and b = 1.908 for the VSCC family.
To compare the VSCC penetration curve with the WINS im-
pactor penetration curve, data from seven independent repeated
tests of the VSCC penetration curve are compared to data from
seven independent tests on the clean WINS impactor (data taken
from Kenny et al. 2000) in Figure 2. Means and standard devi-
ations of penetration values are shown. In the tests carried out
at HSL the WINS was found to have an average D50 value of
2.48 µm and a sharpness value of 1.22. The results of the VSCC
final design tests give a cutpoint of D50 = 2.50 µm at a flow
rate of 16.67 l min−1 , and a sharpness value of 1.16. Note that
Figure 2. Comparison of WINS and VSCC showing curves
fitted to data.
the mean HSL penetration curve for the WINS impactor is not
quite as sharp as the ideal WINS curve published by Peters et al.
(2001a). However, it should be noted that the ideal USEPA curve
was of necessity derived by fitting the fairly small dataset from
initial USEPA tests on the WINS, whereas the USEPA have since
obtained many additional data (see, for example, Vanderpool
et al. 2001a,b). When all the USEPA WINS data are pooled the
resulting fitted curve is indistinguishable from the HSL WINS
data in Kenny et al. (2000). The VSCC penetration curve does
not deviate significantly from the WINS curve, and the VSCC
sharpness value is as good as the WINS.
Testing the VSCC under Loading
Dust-loading tests were conducted on the VSCC in line with
the criteria for Class II equivalency designation set out by USEPA
40 CFR part 53. This describes the dust-loading protocol to be
followed. The candidate device is challenged with a concen-
tration of ISO fine test dust, which is equivalent to an ambient
concentration of 150 µg m−3 over a 24 h period. After “critical”
loading periods of 14 days, 30 days, and 90 days, the candidate
device should show no significant signs of change in cutpoint or
sharpness of cut values.
As it is difficult to generate consistent dust concentration at
levels as low as 150 µg m−3 for periods of up to 90 days, higher
concentrations of test dust were generated for shorter intervals to
give equivalent 24 h exposures of 150 µg m−3 . This procedural
change was agreed with the USEPA prior to the tests being car-
ried out. The dust-loading tests were carried out inside the same
chamber used to perform the VSCC penetration tests. This was
to ensure that the cyclone was moved as little as possible during
the tests, so that coarse particles deposited inside the cyclone
would not become dislodged as a result of movement. This is
important because the oversize dust inside the VSCC collects
on dry deposition surfaces and could possibly be disturbed after
sampling.
The test dust used to load the VSCC was ISO 12103-1 fine
(commonly referred to as Arizona Road Dust or ATD by the
 VSCC DESIGN AND DESIGNATION
USEPA). The dust was generated inside the chamber using a
Wright dust feed (WDF), which was serviced before use and
was fitted with the tungsten-carbide-tipped blade. The dust emit-
ted from the WDF entered the chamber at the top, where it
was mixed and neutralized using an ionizer fan. It then passed
through aluminum honeycomb into the working section. The
WDF was set to the minimum speed at which it would operate
consistently (0.05 rpm) and the dispersion air was set to 0.5 bar
pressure. At this speed the WDF should run for around 60 h
before requiring refilling. The air flow through the chamber was
adjusted using a butterfly valve situated at the base of the cham-
ber to give a concentration of approximately 10 mg m−3 inside
the working region. Exposure at this concentration for approx-
imately 20 min would simulate a 24 h test at 150 µg m−3 . The
air velocity through the chamber was less than 0.04 ms−1 .
The dust concentration inside the chamber was measured us-
ing two thin-walled samplers set up according to the Agarwal
and Lui (1980) criteria. These were fitted with 25 mm GF/A
glass fiber filters, and the dust-laden air was pulled through at
4 l min−1 using Rotheroe and Mitchel sampling pumps. At the
same time, the temporal variation in concentration was moni-
tored using the Microdust 880 nm direct-reading dust monitor.
The Microdust 880 is calibrated in the factory using ATD, and in
these tests the calibration could be reverified using the gravimet-
ric measurements. The calibrated Microdust 880 nm was used to
calculate the exposure time required at any given concentration
to give the equivalent 150 µg m3 24 h exposure.
An important consideration in producing valid test results
during loading is producing the correct size distribution. If a very
fine aerosol is being produced, then the dust will pass through
the VSCC and the tests will overestimate the cyclone’s required
cleaning interval. Similarly, if the aerosol is too coarse, a large
fraction of the mass will be removed by the PM10 inlet up-
stream of the size selector, and the cleaning interval may again
be overestimated. For this reason the size distribution inside the
chamber was measured using a Sierra 8-stage impactor.
Throughout the loading tests, the VSCC was fitted with the
USEPA standard PM10 lo-flow Dichotomous inlet and was op-
erated at a calibrated volumetric flow rate of 16.67 l min−1 . The
dust penetrating the cyclone was collected on a 47 mm GF/A
filter mounted inside a FRM cassette at the outlet of the cyclone.
The test protocol agreed with EPA was as follows:
1. Verify the penetration performance curve of the clean cy-
clone using standard glass microspheres.
2. Generate a concentration of approximately 10 mg m−3
ISO 12103-1 fine test dust into the chamber, measure the
concentration using the thin wall samplers, and calibrate
the Microdust 880 nm dust monitor. Determine the mass
median diameter and standard geometric standard devia-
tion of the test dust using the cascade impactor.
3. During each loading test, monitor the dust concentration
inside the chamber using the calibrated Microdust 880 nm
to predict the required sampling period.
19
Figure 3. Effect of dust loading on VSCC D50 and sharpness
of cut.
4. Carry out penetration tests corresponding to loading in-
tervals of 1, 2, 3, 4, 14, 30, and 90 days at an equivalent
daily concentration of 150 µg m−3 .
The intention of the test schedule was to verify the ability of
the VSCC to perform within EPA criteria. The key tests were
those verifying a two-week cleaning interval, a 30-day cleaning
interval, and a 90-day interval. Penetration curves for the VSCC
cyclone after the various loading intervals were analyzed, and
the relationship of D50 and sharpness to exposure interval (at
an equivalent concentration of 150 µg m−3 ) is shown in Fig-
ure 3. The results indicate that the VSCC can operate at a dust
concentration of 150 µg m−3 for at least 90 days without any
significant change in the cyclone cutpoint. A small increase in
the sharpness value (i.e., decrease in sharpness) was observed
over the same period.
In order to assess the impact of loading the VSCC cyclone
on apparent PM2.5 concentrations, numerical simulation was uti-
lized to “sample” the three ambient aerosol distributions cited
in the Federal Register. Numerical integration of the penetration
curves with the aerosol size distributions was used to calculate
the mass of particulate that would be collected, first with the
VSCC cyclone and then with a fractionator following the “ideal”
PM2.5 curve (as specified in the FRM). The bias between VSCC
and “ideal” FRM was calculated from the results. A detailed
discussion of how these calculations are performed has been
presented by Kenny et al. (2000). Calculations were made for
each VSCC penetration curve corresponding to different loading
times (1, 2, 3, 7, 15, 30, and 90 days). These calculations showed
that biases between the VSCC and “ideal” samplers would be
expected to be less than 1% for fine and typical aerosols, even
with loadings up to 90 days. For the coarse aerosol, the VSCC
sampling bias was between +2 and +3% for all loadings up to 90
days. Note that bias values in the range−5% to +5% are permis-
sible for FRM or FEM samplers, and the VSCC easily passes this
performance requirement even after 90 days of continuous op-
eration at an equivalent concentration of 150 µg m−3 . The small
20 L. C. KENNY ET AL.
positive bias for coarse aerosol is due in part to coincidence-
related measurement error in the tail of the penetration curve,
which is very difficult to eliminate entirely for measurements
made with our method (using the APS 3310). For comparison,
similar tests and data treatment procedures on the WINS im-
pactor data also produce a positive bias exceeding 1% for the
clean WINS impactor (Kenny et al. 2000).
FIELD COMPARISON OF THE VSCC AND WINS-BASED
PM2.5 SAMPLERS
Test Requirements
The Federal Register requires field tests to be carried out at
two sites for Class II candidate equivalent methods. Require-
ments regarding the test conditions at the sites are stringent and
difficult to meet given the variable nature of pollution episodes.
The aerosol size distribution must be such that all acceptable
sample sets from one site must have a PM2.5 /PM10 ratio greater
than 0.75, while at the other site they must have a ratio less than
0.40. The concentration must be such that at the first site (ratio
>0.75), a minimum of 3 acceptable sample sets must have an
average PM2.5 concentration >40 µg m−3 (for 24 h samples),
and a minimum of three acceptable sample sets must have an
average PM2.5 concentration <40 µg m−3 (for 24 h samples),
as measured by the reference method. At the second site (ratio
<0.40), a minimum of 3 acceptable sample sets must have an
average PM2.5 concentration >30 µg m−3 (for 24 h samples),
and at least three acceptable sample sets must have an average
PM2.5 concentration <30 µg m−3 (for 24 h samples). For each
site, at least 10 acceptable sample sets must be obtained. To be
considered acceptable, sample sets must be in the range of 10–
200 µg m−3 . Also, the precision of the reference method mea-
surements must be less than specified maximum values. These
requirements mean that sampling sites and seasons must be care-
fully chosen and that several extra test days are built in to ensure
that sufficient acceptable datasets are obtained.
The USEPA requires a minimum of 3 reference method and
3 candidate method samplers to be set up and operated at each
test site, with each set of measurements consisting of 3 reference
and 3 candidate measurements, all obtained simultaneously. All
measurements must be either 24 or 48 h integrated measure-
ments. A minimum sample period of 23 h is required for both
the reference and candidate methods. At least two PM10 samplers
must be operated simultaneously with the candidate and refer-
ence methods to determine the PM2.5 /PM10 ratio. The equiv-
alency requirements specify a correlation coefficient of greater
than 0.97 between candidate FEM and the FRM, and a precision,
defined as the standard deviation of three collocated candidate
FEM instruments, of less than 2 µg m−3
Test Methodology
For the VSCC equivalency field trials, sampling locations in
Hartford, CT and Phoenix, AZ were used. The Hartford trials
were conducted first by USEPA contractor Research Triangle
Institute (RTI) as part of a larger series of tests. The Phoenix,
AZ “super site” was then chosen for the second set of trials
after discussion of historical field test data with EPA and the
Technical Review Board. The Phoenix Super Site has been in
operation for nearly 15 years, and is typically impacted by fine
ambient PM from urban activity as well as coarse wind-blown
particulate from the surrounding desert. This site and the one at
Rubidoux, CA are two historical sampling sites that have been
repeatedly used to test equipment due to their difficult aerosol
and climate conditions.
At each field site the following Lo-Vol PM2.5 and PM10 sam-
plers were operated daily:
Three BGI PQ200 PM2.5 FRM with WINS EPA
Three Impactor, three (at AZ: 2 at CT) BGI PQ200 Candidate
PM2.5 FEM with BGI VSCC
Three Cyclone, and three BGI PQ200 PM10 Low-Vol FRM
Samplers.
These samplers were set up in three rows, collocated on a
single sampling platform meeting the site criteria for spacing,
inlet height of 2 m, and operating parameters as stated in the
CFR. A tenth FRM sampler was utilized for special-purpose
sampling and as a backup sampler if one of the other nine low-
flow samplers had a problem. This special-purpose sampler was
utilized for PM1 sampling and the data taken for the purpose of
comparing PM10 , PM2.5 , and PM1 concentrations.
A 22/23 h sampling time (the minimum acceptable) was used
to allow testing on sequential daily operation with a view to com-
pletion of the entire test cycle within ∼20 days. For days with low
concentrations of PM2.5 the 23 h sample time could be extended
to 48 h in an attempt to meet the required minimum or higher
concentration averages. The flow rate, ambient temperature, and
barometric pressure of samplers was checked throughout using a

R
DeltaCal calibrator. Gelman TefloTM PTFE (TeflonTM ) mem-
brane filters were utilized in all samplers in the Phoenix field
test. The presample and postsample mass of the filters was mea-
sured on a Sartorius Model C5 microbalance. USEPA guidelines
regarding FRM filter preparation and analysis were rigorously
followed throughout.
On completion of the 23 h sample event, each sampler stopped
sampling and displayed the summary screen of data, including
date, time, sample volume, ambient temperatures, barometric
pressure, and system pressures. All these data were recorded
manually onto “Single Filter PM2.5 Sampler Run Data Sheets”
for each of the nine samplers and each of the sample events. Lo-
cal meteorology notes were made, and observations were noted
on any aspect that may have been of later use in interpretation
of the data. Each sampler was visited by the operator within the
1 h window of time between sample events. The sample filter
with mass was collected and placed back into each metal trans-
port container, and a new clean filter was placed in the sampler
ready for the new sample event. All pertinent data were recorded
and the requirements for flow rate and volume were met. The
operator stayed at the site until the new sample event began and
verified that all the samplers started and were operating correctly.
 VSCC DESIGN AND DESIGNATION
In addition to each sample event, the operator periodically would
remove the PM10 inlet and place a BGI DeltaCal flow calibrator
on each sampler to verify the actual sample rate was correct at
the onset of sampling.
Results of the Field Comparisons
A total of 33 data sets were obtained at the Hartford, CT site;
however, the PM2.5 /PM10 ratio was <0.40 for only 3 of the test
days, and those 3 data sets had an average PM2.5 concentration
below the lower acceptable limit of 10 µgm−3 . Thus, the data
sets did not meet the USEPA requirements for a site having
PM2.5 /PM10 ratios <0.40. This result determined the choice of
Phoenix, AZ as the second field site.
The PM2.5 /PM10 ratio was >0.75 for 11 of the 33 data sets
from CT, and of these 11 data sets, the average PM2.5 concentra-
tion (as determined by the reference method) was <40 µg m−3
for 10 data sets. The precision of the reference method measure-
ments for all 10 of these data sets was well within the acceptable
bounds, thus meeting the required minimum of 3 acceptable data
sets with PM2.5 less than 40 µg m−3 . That left only 1 of the data
sets having average PM2.5 concentration greater than 40 µg m−3 ,
whereas the rules require a minimum of three data sets at high
concentration. Therefore, the data did not strictly meet the re-
quirements for a site having PM2.5 /PM10 ratios greater than 0.75
with at least 3 of the acceptable data sets having PM2.5 concen-
trations greater than 40 µg m−3 . However, one of the data sets
had a PM2.5 /PM10 ratio of 0.73 and average PM2.5 concentration
of 38 µg m−3 , both of which are within 95% of acceptable. The
next-closest data set had a PM2.5 /PM10 ratio of 0.73 (97% of
0.75) and an average PM2.5 concentration of 31 µg m−3 (77%
of 40). The precision of the reference method measurements for
both of these data sets was also acceptable. At least 11 data sets
were fully acceptable, thereby meeting the requirement for a
minimum of 10 acceptable data sets for the site.
The regression parameters (slope, intercept, and correlation
coefficient) were calculated for both the 11 sets of data that were
fully acceptable and for the 13 sets of data that included the two
additional data sets that almost met the ratio and concentration
requirements that are needed for the minimum of 3 in the “over
40 µg m−3 ” category. All three performance parameters for both
data sets were well within the specified limits (see Table 1).
Table 1
Summary of results from the field comparisons of WINS and
VSCC samplers
CT data: CT data: Phoenix data: USEPA
11 data 13 data 15 data performance
sets sets sets requirement
Slope 1.013 1.005 1.04 1 ± 0.05
Intercept 0.17 0.23 0.859 0±1
R2 0.9993 0.9991 0.970 >0.97
21
Figure 4. Field comparison of VSCC and WINS PM2.5.
A total of 15 sets of data were obtained from the Phoenix
site, and the PM2.5 /PM10 ratio was <0.40 throughout. However,
the PM2.5 concentration only exceeded the minimum acceptable
level of 10 µg m−3 on three of these days, and on no day did
it exceed 30 µg m−3 . The precision of the reference method
measurements for all data sets was within acceptable bounds
on all 15 days. The low concentrations at Phoenix mean that
the data do not strictly meet the USEPA requirements for a site
having PM2.5 /PM10 ratios less than 0.40.
The regression parameters (slope, intercept, and correlation
coefficient) were calculated for all 15 sets of data. The bias
between the VSCC- and WINS-based samplers at the Phoenix
site, i.e., slope of regression line, was slightly higher than the
value of 2–3% predicted from numerical integration, but still just
within the upper limit of 5% allowed by USEPA. The intercept
and correlation coefficient were also within the specified limits
(see Table 1). A graph of all the field test results from both
Hartford, CT and Phoenix, AZ is plotted in Figure 4.
DISCUSSION
The laboratory measurements of the penetration curve of the
VSCC show that it is at least as sharp as the WINS impactor
(when clean) and, if anything, somewhat sharper than the WINS
in the sub-2.5 µm range. The VSCC has been demonstrated to
retain its D50 and sharpness under conditions of heavy loading,
whereas the WINS is known to suffer loading effects after rel-
atively short periods of use at high concentration (Kenny et al.
2000). The effect of loading the WINS is to decrease the D50 cut-
point and also to decrease the sharpness, thus leading to negative
bias in sampled PM2.5 concentrations. These known character-
istics of the two size selectors might lead one to expect a small
positive bias between the VSCC and WINS PM2.5 data from
field comparisons at high concentrations.
In the Hartford, CT field comparisons the aerosol size distri-
bution, as indicated by the PM2.5 /PM10 ratio, was typical to fine,
and there was no significant bias observed between the VSCC
and WINS. Under the conditions pertaining to this test the WINS
would not be expected to manifest any measurable loading bias.
22 L. C. KENNY ET AL.
In the Phoenix, AZ field comparisons the aerosol size distribu-
tion was coarse throughout but the concentration was very low,
leading to higher experimental errors as a result of the low filter
masses collected. The results show a small positive bias between
the VSCC and WINS that could not reasonably be attributed to
WINS loading effects at the concentrations experienced. The
bias is too small to be considered significant in terms of the re-
quired performance characteristics and given the small number
of data sets does not significantly differ from zero.
The field comparisons reported here highlight the difficulty
of performing the equivalency tests strictly as required by EPA.
In both field locations, one would need to plan a very lengthy
sampling campaign in order to meet the USEPA’s stringent data
requirements for results with concentrations above 40 µg m−3
and 30 µg m−3 . This adds greatly to what is already a very
resource-intensive and hence expensive test protocol. On the
basis of the data we have presented, one can argue that the data
sets at high concentrations are not necessary if those obtained at
low concentrations meet the performance requirements. In par-
ticular, there is not a strong case for excluding datasets with con-
centrations below 10 µgm−3 , which are supposed to be subject
to greater experimental error, where those data clearly meet the
requirements for precision. Naturally, different considerations
would apply to field tests of continuous monitors, for which
loading effects would cause biases after extended use at high
concentrations.
CONCLUSIONS
A VSCC cyclone selector for PM2.5 has been developed and
tested in both laboratory and field situations. The VSCC selec-
tor is at least as sharp as the WINS impactor when clean, and
its size-selection characteristics are remarkably stable when it
is subjected to loading. This contrasts with the known charac-
teristics of the WINS impactor, which is known to suffer from
serious loading effects on prolonged use. The VSCC was sub-
mitted for designation as a Class II Federal Equivalent Method
and subjected to field comparisons with the WINS FRM at two
different sites. The field tests covered a range of conditions as
regards aerosol size distribution; however, concentrations were
generally lower than required. Nevertheless, the data from both
sites met the USEPA performance requirements for equivalency.
Following extensive negotiation, the USEPA was persuaded to
waive the three minor failures of the field data to meet all Class
II FEM test requirements and, accordingly, consider the VSCC
fully acceptable based on the excellent regression parameters
determined for the candidate method.
REFERENCES
Agarwal, J. K., and Lui, B. Y. H. (1980). A Criterion for Accurate Aerosol
Sampling in Calm Air, J. Am. Ind. Hyg. Assoc. 41:191–197.
BGI Instruments. (2002). Version 1.3, Very Sharp Cut CycloneTM VSCC, Instruc-
tions for Use and Maintenance.
Federal Register. (1987). Ambient Air Monitoring PM-10 Reference and Equiva-
lent Methods. United States Environmental Protection Agency, Federal Reg-
ister 40CFR Part 53, July 1987.
Federal Register. (1997). Revised Requirements for Designation of Reference
and Equivalent Methods for PM2.5 and Ambient Air Quality Surveillance for
Particulate Matter: Subpart F—Procedures for Testing Performance Charac-
teristics of Class II Equivalent Methods for PM2.5, Federal Register 40 CFR
Parts 53 and 58, 18, July 1997.
Federal Register. United States Federal Protection Agency. (2002). Ambient Air
Monitoring Reference and Equivalent Methods. Designation Notice of VSCC.
2 April 2002.
Kenny, L. C., and Gussman, R. A. (1997). Characterisation and Modelling of a
Family of Cyclone Aerosol Preseparators, J. Aerosol. Sci. 28(4):677–688.
Kenny, L. C., and Gussman, R. A. (2000). A Direct Approach to the Design of
Cyclones for Aerosol Monitoring Applications, J. Aerosol Sci. 31(12):1407–
1420.
Kenny, L. C., Gussman, R., and Meyer, M. (2000). Development of a Sharp-Cut
Cyclone for Ambient Aerosol Monitoring Applications, Aerosol Sci. Technol.
32:338–358.
Maynard, A. D., and Kenny, L. C. (1995). Sampling Efficiency Determination
for Three Models of Personal Cyclone, Using an Aerodynamic Particle Sizer,
J. Aerosol Sci. 26(4):671–684.
Peters, T. M., Gussman, R., Kenny, L. C., and Vanderpool, R. W. (2001b).
Evaluation of PM2.5 Size Selectors Used in Speciation Samplers, Aerosol
Sci. Technol. 34:422–429.
Peters, T. W., Vanderpool, R. W., and Wiener, R. W. (1996). Development and
Evaluation of Sampling Components for Measuring Particulate Matter Under
2.5 Micrometers, RTI Report 6360-001.
Peters, T. W., Vanderpool, R. W., and Weiner, R. W. (2001a). Design and Cal-
ibration of the EPA PM2.5 Well Impactor Ninety Six (WINS), Aerosol Sci.
Technol. 34:389–397.
Schwartz, J., Dockery, D. W., and Neas, L. M. (1996). Is Daily Mortality Asso-
ciated Specifically with Fine Particles? J.A & WMA. 46:927–939.
Smith, W. B., Wilson, R. R., and Bruce, D. B. (1979). A Five-Stage Cyclone
System for in situ Sampling, Environ. Sci. Technol. 13(11):1387–1392.
Tolocka, M. P., Peters, T. M., Vanderpool, R. W., Chen, F. L., and Wiener,
R. W. (2001). On the Modification of the Low Flow-Rate PM10 Dichotomous
Sampler Inlet, Aerosol Sci. Technol. 34:407–415.
Vanderpool, R. W., Peters, T. M., Natarajan, S., Gemmill, D. B., and Weiner,
R. W. (2001a). Evaluation of the Loading Characteristics of the EPA WINS
PM2.5 Separator, Aerosol Sci. Technol. 34:444–465.
Vanderpool, R. W., Peters,T. M., Natarajan, S., Tolocka, M. P., Gemmill, D. B.,
and Weiner, R. W. (2001b). Sensitivity Analysis of the USEPA WINS PM2.5
Separator, Aerosol Sci. Technol. 34:465.