From:		Jenkins, Paul <paul.jenkins@deq.virginia.gov>
Sent:		Thursday, January 16, 2020 10:19 AM
To:		Mary-Jo Caldwell
Subject:	Re: Revised summary of our communication regarding catalyst testing
Yes, that appears to accurately reflect our conversation.
Paul

On Thu, Jan 16, 2020 at 10:17 AM Mary-Jo Caldwell <mjcaldwell@nc.rr.com> wrote:
Paul,
Below I have provided a revised summary of our communication regarding catalyst testing.  Please confirm that it accurately represents our conversations. 
As I mentioned on the phone on January 14, 2020, I am working with the U.S. EPA on the Residual Risk analysis for the Paper and Other Web Coating (POWC) NESHAP.  As part of that effort, we are estimating the cost of requiring annual catalyst testing for catalytic oxidizers used in the POWC industry.  I called you to discuss these costs, and this email summarizes our discussion.  Please review the information below, and confirm that it accurately represents our conversation.
I called you because you are listed as the permit contact in the 2008 Statement of Basis for the CPFilms Fieldale facility.  Their permit requires annual testing of the catalyst, and I asked you if you had an estimate of the cost of such catalyst testing.
You indicated that although VADEQ does not have formal guidance that requires annual testing of the catalyst in catalytic oxidizers, it is common practice for your region to include this requirement in permits.  You indicated that you believe most if not all of the permits that your region has written do include this requirement, but that you could not guarantee this for older permits or for all permits in Virginia without checking.  
You said you did not have an estimate of the associated costs of such testing.  However, you indicated that when you worked at Wolverine Gasket in Blacksburg, Virginia, which used a catalytic oxidizer, the catalytic oxidizer manufacturer tested the catalyst annually.  To your recollection, the testing was done at no cost to the facility, and you said you thought annual catalyst testing may have been part of the warranty.
Thank you for your review of our conversation.
Mary-Jo
 
Mary-Jo Caldwell
Caldwell Environmental, Inc.
6205 Winthrop Drive
Raleigh, NC 27612
919-812-5309
