UNITED STATES ENVIRONMENTALPROTECTION AGENCY
                            RESEARCH TRIANGLE PARK, NC  27711

                                       SEP  26  2007
MEMORANDUM
                                                                            ANDSTANDARDS

SUBJECT:   Use of New ASTM Performance Vjpfieqtions for Baghouse Media

FROM:      Stephen D, Page, Dire
              Office of Air Quality Plannrag and Stagjprds

TO:          Regional Air Division Directors
       The Office of Air Quality Planning and Standards (OAQPS) is the delegated Agency
authority for approving more advanced alternatives to emission test methods specified in 40 CFR
Parts 50, 61, and 63 for stationary sources. As part of this responsibility, we actively encourage
the development, verification, and application of new approaches that provide better emissions
monitoring and control information from regulated sources in more continuous, more objective,
more accurate, or more inexpensive formats. This approach has been strongly encouraged and
recommended in reports by both the National Academy of Science and the Government
Accountability Office.

       Over the past ten years, OAQPS has collaborated closely with EPA's Office of Research
and Development in the Environmental Technology Verification Program (ETV) to verify the
performance of air pollution monitoring and control technologies.  One recent ETV project
provided bag-house media vendors with objective third-party verifications of the performance of
their products. Their bag-house media were verified for penetration of PM2.5 total particulate
matter, and operating pressure drop. The test procedures were developed with a diverse group of
stakeholders and incorporated into the "Generic Verification Protocol for Baghouse Filtration
Products " located at http://www.epa. gov/etv/pdfs/vp/05_vp_bfp.pdf. Completed verifications of
bag-house media can be found at http://www.epa.gov/etv/verifications/verification-index.html.

       The ETV protocol was used as the basis for ASTM Standard D6830-02.  Characterizing
the Pressure Drop and Filtration Performance of Cleanable Filter Media." Also, the International
Standards Organization (ISO) has proposed a similar version which is currently moving through
the ISO approval process.

       The South Coast Air Quality Management District (SCAQMD) has followed the ETV
and ASTM verification programs and adopted Rule 1156: PM Reductions for Cement Industries
on Noveinber 4,2005. This Rule strongly encourages the use of "verified bag-house fabrics" to
                              Internet Address (URL) • http://www.epa.gov
            Recycled/Recyclable 'Printed with Vegetable Oil Based Inks on RecycledPaper (Minimum 25% Postconsumer)

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control particulate einissions from cement manufacturing facilities.  Paragraph (e) (7) of the rule
reduces the frequency of compliance testing from one year to five for those facilities having
"verified bag-house fabrics."  Discussions with SCAQMD personnel indicate this approach is
successful in encouraging the use of quality bag filter media. Anticipating more interest in these
verifications by regulators, bag-house manufacturers and vendors are undertaking increased
testing of their bag-house fabrics using the ETVIASTM protocol.

       We believe that use of this protocol encourages use of high performance bag-house filter
materials and encourages better quality construction.  When combined with good Compliance
Assurance Monitoring (CAM) procedures, there will be more confidence in the overall
environmental performance of bag-house installations.

       Where appropriate, we plan to consider the ETVIASTM protocol in future federal
regulations.  I encourage you in the Regional Offices  to consider opportunities to employ these
protocols in  State and local agency regulatory programs and to suggest that their bag-house
installations use filter media tested using the ETVIASTM protocol as documented in ASTM
Standard D6830.  I would appreciate your help in facilitating the use of this verification approach
in your State, Local, and Tribal programs.

       Tom Logan (919-541-2580) or John Bosch (919- 541-5583) can provide further detail on
this subject if you have questions.

Gregory Green (C304-01)
William Harnett (C504-01)
Mike Kosusko (E343-02)
Peter Tsingotis (D205-01)
Chet Wayland (C304-02)
Lydia Wegman ((304-02)
RO Air Branch Chiefs

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