UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029





	 ADVANCE \x15 DATE: 

SUBECT:

	February 10, 2009

Technical Support Document (TSD) for Direct Final Rulemaking
Notice—Virginia;  Volatile Organic Compound Reasonably Available
Control Technology for Reynolds Consumer Products Company 



 ADVANCE \x15 FROM:

	Irene Shandruk, Environmental Scientist

        /s/

 ADVANCE \x15 TO:

	Virginia; Docket No. EPA-R03-OAR-2009-0093

 ADVANCE \x15 THRU:

	Cristina Fernandez, Chief        /s/

Air Quality Planning Branch



A. BACKGROUND

	The Clean Air Act (CAA) 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 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 section 182 of the Clean Air Act.  As part of the
original attainment plan, one of the sources located in the area
identified as being subject to non-CTG RACT was Reynolds Metals Company.
 The company’s Richmond Foil Plant produces aluminum foil by rolling
aluminum into very thin sheets.  VOC emissions at this plant come from
lubricants used on 16 foil rolling mills.

The facility underwent RACT analysis, and a consent order was issued to
the facility on December 18, 1987.  The order was then submitted to EPA
as a SIP revision, and approved into the Commonwealth’s SIP on August
20, 1990 (55 FR 33904).  Since 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, and a change
to the facility’s RACT requirements necessitates a change in the SIP.

Under the original analysis, Reynolds determined that the use of linear
paraffin with twelve or more carbon atoms and maintaining oil
temperatures below 150°F was RACT.  This approach was approved in a
Consent Agreement and Order (effective on September 30, 1987), and
subsequently incorporated into the SIP on August 20, 1990 (55 FR 33904).
 Recently, due to cost and availability of linear paraffin, Reynolds
seeks the option of using less expensive and more readily available
substitutes should the need arise.  A state operating permit has been
drafted to ensure compliance with the non-CTG RACT requirements of
Article 51 of 9VAC5-40 (Existing Stationary Sources).  The permit is
intended to replace the consent order for the facility, and therefore
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
section 182 of the Clean Air Act.  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 section
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 section 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

Due to cost and availability of linear paraffin, Reynolds Consumer
Products Company seeks the option of using less expensive and more
readily available substitutes in their 16 foil rolling mills should the
need arise.  A state operating permit has been drafted to ensure
compliance with the non-CTG RACT requirements of Article 51 of 9VAC5-40
(Existing Stationary Sources).  The permit is intended to replace the
consent order for the facility.

Therefore, a SIP revision request concerning this RACT permit was
submitted to EPA on October 20, 2008 and received by EPA on October 24,
2008.  Pursuant to the requirements of Section 110 of the CAA, Virginia
is requesting approval of a SIP revision, which was approved by the
Commonwealth and became effective on October 1, 2008 under the authority
of section 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 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 Reynolds Consumer Products Company located in Richmond,
Virginia.  The submittal is for the purpose of meeting the requirements
for RACT in order to implement the maintenance plan 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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