UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029





	 ADVANCE \x15 DATE: 

SUBECT:

	November 19, 2007

Technical Support Document (TSD)—Virginia;  Control of Volatile
Organic Compound (VOCs) Emissions from the Kraft Foods Global, Inc.—
Bakery located in Henrico County, Virginia



 ADVANCE \x15 FROM:

	Irene Shandruk, Environmental Scientist     /s/

 ADVANCE \x15 TO:

	Virginia; Docket No. EPA-R03-OAR-2007-1139

 ADVANCE \x15 THRU:

	Cristina Fernandez, Chief       /s/

Air Quality Planning Branch



A. BACKGROUND

	The federal Clean Air Act requires that Virginia adopt and enforce a
plan, known as the State Implementation Plan (SIP), to attain and
maintain the National Ambient Air Quality Standards (NAAQS) throughout
the Commonwealth.  In 1985, a plan to attain and maintain the 1-hour
ozone air quality standard in the Richmond Nonattainment Area was
adopted.  The 1985 plan provided that the State Air Pollution Control
Board must, on case-by-case basis, determine whether there is a
reasonably available control technology (RACT) to reduce volatile
organic compound (VOC) emissions from major sources for which the
Environmental Protection Agency (EPA) has not issued a control
technology guideline (CTG).

Under the 1-hour ozone standard requirements established by the Clean
Air Act (CAA) Amendments of 1990, the Richmond area was designated as a
moderate nonattainment area.  The area’s air quality improved, and a
redesignation request and maintenance plan were sent to EPA and approved
on November 17, 1997 (62 FR 61237).  On July 18, 1997, EPA promulgated a
new 8-hour NAAQS for ozone.  On September 22, 2004, under this new
standard, the Richmond area was classified as a marginal nonattainment
area.  On September 20, 2006, the Virginia Department of Environmental
Quality (VADEQ) formally submitted a request to redesignate the Richmond
area from nonattainment to attainment of the 8-hour NAAQS for ozone.  On
September 25, 2006, the VADEQ submitted a maintenance plan for the
Richmond area as a SIP revision to ensure continued attainment.  The
redesignation request and maintenance plan were approved on June 1, 2007
(72 FR 30485).

Section 107(d)(3)(E) of the CAA stipulates that for an area to be
redesignated, EPA must approve a maintenance plan that meets the
requirements of Section 175A.  All applicable nonattainment area
requirements remain in place.  The maintenance plan constitutes a SIP
revision, and must provide for maintenance of the relevant NAAQS in the
area for at least 10 years after redesignation.  Virginia developed a
maintenance plan that meets all EPA requirements and demonstrates that,
because of permanent and enforceable measures, emissions will remain
within the regional emissions budget while allowing for growth in
population and vehicle miles traveled.  The plan includes a
demonstration that emissions will remain within the 2005 levels for a
10-year period by keeping in place key elements of the current federal
and state regulatory programs, including case-by-case RACT requirements
for the area.

RACT is the lowest emission limit that a particular source is capable of
meeting by the application of control technology that is reasonably
available with the consideration of technological and economic
feasibility.  When the Richmond area was originally designated as an
ozone nonattainment area under the 1-hour ozone standard, it was
classified as “moderate” and thereby had to meet the non-CTG RACT
requirements of § 182.  As part of the 1-hour ozone standard attainment
plan, one of the sources located in the area identified as being subject
to non-CTG RACT was Nabisco Brands (now Kraft Foods).  Cookies,
crackers, and pretzels are produced at this plant using two different
dough processes: sponge-dough and straight-dough.  In the sponge-dough
process, doughs are formulated by yeast leavening; while in the
straight-dough process, doughs are leavened chemically in the absence of
yeast.  The sources of VOC emissions at this plant are proof-room,
ovens, and oil treatment facilities.

The facility underwent RACT analysis, and a federally-enforceable state
operating permit was issued to the facility, which became effective on
April 24, 1991.  The permit was then submitted to EPA as a SIP revision,
and approved into the Commonwealth’s SIP on March 6, 1992 (57 FR
8080).  Because the Richmond area in which this facility is located has
continuously been classified as either a nonattainment or a maintenance
area, the RACT requirements remain in effect. In 2006, Kraft made a
number of modifications to its process that necessitated revisions to
its RACT permit.  Therefore, change to the facility’s RACT permit
necessitates a change to the SIP.

B. EPA REQUIREMENTS

	

When the Richmond area was originally designated as an ozone
nonattainment area under the 1-hour ozone standard, it was classified as
moderate and thereby had to meet the non-CTG RACT requirements of §
182.  Under the 8-hour ozone standard the Richmond nonattainment area
was designated as marginal.  Under Section 182(b) of the CAA, stationary
sources in moderate nonattainment areas must comply with the
requirements for sources in marginal nonattainment areas.  The
additional, more comprehensive control measures in § 182(b)(2)(B)
require that existing stationary sources emitting VOC for which a CTG
existed prior to adoption of the 1990 Amendments also use RACT.  Section
182(b)(2)(C) requires RACT controls on major VOC stationary sources not
covered by an existing CTG.  A major source in a nonattainment area is
defined in § 302(j) to be a stationary source emitting or having the
potential to emit 100 tons per year (tpy) or more of a pollutant. 

C. EVALUATION OF STATE SUBMITTAL

In 2006, Kraft made a number of modifications to its process that
necessitated revisions to its RACT permit.  Therefore, a SIP revision
request concerning this RACT permit was submitted to EPA on October 29,
2007 and received by EPA on November 1, 2007.  Pursuant to the
requirements of Section 110 of the CAA, Virginia is requesting approval
of a SIP revision, which was approved by the State and became effective
on September 19, 2007 under the authority of § 10.1-1185 of the Code of
Virginia, and submitted in accordance with the requirements of 40 CFR
Part 51 (Requirements for Preparation, Adoption, and Submittal of
Implementation Plans).

The revision consists of a federally enforceable state operating permit
(which was drafted in compliance with the non-CTG RACT requirements of
Article 51 of 9 VAC 5 Chapter 40) containing terms and conditions for
the control of emissions of VOCs from the Kraft Foods Global,
Inc.—Richmond Bakery located in Henrico County, Virginia.  The
submittal is for the purpose of meeting the requirements for RACT in
order to implement the attainment and maintenance plans for the Richmond
8-hour ozone maintenance area.

D. RECOMMENDATION

Virginia has met the requirements for submitting a RACT SIP revision.  
SEQ CHAPTER \h \r 1 The revision will result in the Richmond 8-hour
ozone maintenance area in being able to implement its attainment and
maintenance plans. Therefore,   SEQ CHAPTER \h \r 1 EPA approval of this
SIP revision is recommended.

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