Molly Joseph Ward 

Secretary of Natural Resources 

COMMONWEALTH of VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Street address: 629 East Main Street, Richmond, Virginia 23219 

Mailing address: P.O. Box 1105, Richmond, Virginia 23218 

Fax (804) 698-4500 TOO (804) 698-4021 

www.deq. virginia.gov 

OCT 2 6 2015 

Ms. Diana Esher, Director 

Air Protection Division (3APOO) 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

David K. Paylor 

Director 

(804) 698-4020 

1-800-592-5482 

Reference: SIP Revision for Reynolds 

Consumer Products 

Dear Ms. Esher: 

Pursuant to the requirements of § 11 0 of the Clean Air Act, we are officially requesting 

approval of a revision to the Commonwealth of Virginia State Implementation Plan (SIP) 

approved on February 11,2014 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 oflmplementation Plans). The plan revision is effective upon the date 

of approval, October 20, 2015. 

The revision consists of a federally enforceable state operating permit containing terms 

and conditions for the control of emissions of volatile organic compounds (VOCs) from the 

Reynolds Consumer Products LLC- Bellwood Printing Plant (Registration No. 50260) located 

in Chesterfield, Virginia. The purpose of this revision is to convert a consent order for 

reasonably available control technology (RACT) into a state operating permit. A number of 

technical corrections are being made as well. With this letter we request removal of the original 

consent order from the SIP. 
Enclosed are the following: 

1. SIP revision, including the federally enforceable state operating permit. 

2. Public participation certification and compliance with state administrative procedures. 

3. Summary of public comment and responses thereto. 

If you have any questions or need additional information, please let us know. 

DKP\kgs 

TEMPLATES\SOURCE-SPECIFIC\PLNOO 

RACT\RICHMOND6\RCP-SIP.DOC 

Enclosures 
ENCLOSURE 1

1

COMMONWEALTH OF VIRGINIA

STATE IMPLEMENTATION PLAN REVISION

FOR

RICHMOND MAINTENANCE AREA

STATE OPERATING PERMIT FOR

REYNOLDS CONSUMER PRODUCTS

CHESTERFIELD COUNTY, VIRGINIA

The federal Clean Air Act requires that Virginia adopt and enforce a state implementation 

plan (SIP) for attaining and maintaining the national ambient air quality standards 

(NAAQS) throughout the state. In 1985, a plan to attain and maintain the ozone air 

quality standard in the Richmond Nonattainment Area was adopted which demonstrated 

attainment of the national ozone standard by the end of 1987. 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 federal Clean Air 

Act, 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. Under this new standard, the Richmond

area was classified a moderate nonattainment area. On September 22, 2004, the 

Richmond area was reclassified as a marginal nonattainment area. On September 20, 

2006, the department formally submitted a request to redesignate the Richmond area 

from nonattainment to attainment of the 8-hour NAAQS for ozone, and on September 

25, 2006, the department 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 federal Clean Air Act 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.
2

RACT is the lowest emission limit that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological 

and economic feasibility. Section 182(b) requires stationary sources in moderate 

nonattainment areas to 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.

When the Richmond area was originally designated as an ozone nonattainment area, it 

was classified as "moderate" and thereby had to meet the non-CTG RACT 

requirements of § 182. 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 

Consumer Products LLC – Bellwood Printing Plant in Chesterfield, Virginia. The 

"Group A facilities" at the plant are Presses Number 1, 2, and 4, Extruders Number 1, 

2, and 3, and the treating station for Press Number 3. The reduction in VOC emissions 

from the Group A facilities is not less than 65%, by weight on a daily basis over the 

historical amount of solvent used to apply the same amount of solids. Across line 

averaging of emission reductions is utilized to determine compliance with the specified 

daily emission reduction requirement. 

The facility underwent RACT analysis, and a federally-enforceable consent order was 

issued to the facility on October 30, 1986. The consent order was then submitted to EPA 

as a SIP revision, and approved into the Commonwealth’s SIP on June 6, 1996 (61 FR 

29963). 

Since then, the company discovered two typographical errors in the formula used to 

calculate the daily reduction in VOC emissions. The current definitions for X14 and X15 

are X14 =X14+X5+X6+X7+X8+X9+X10+X11+X12+X13, and X15 =X

14+X0+X1+X2+X3 - X14 - X5 - X6 - X7. These must be corrected to X14 = 

X4+X5+X6+X7+X8+X9+X10+X11+X12+X13, and X15 = X14+X0+X1+X2+X3 - X4 - X5 -

X6 - X7. This change is administrative and will have no effect on facility operation or air 

quality. At the same time, the consent order was converted into a state operating 

permit, which is now the department's preferred way of implementing RACT 

requirements. Again, this change is administrative and will have no effect on facility 

operation or air quality. 

This document presents the RACT permit for the control of VOC emissions. A legally 

enforceable mechanism (federally enforceable state operating permit) has been drafted 

to ensure compliance with the non-CTG RACT requirements of Article 51 of 9VAC5-40 

(Existing Stationary Sources) and is included as Attachment A. Attachment A also

contains the associated engineering analysis.
3

With this SIP submittal, the Commonwealth is requesting that the original consent order

be removed from the SIP.

TEMPLATES\SOURCE-SPECIFIC\PLN01

RACT\RICHMOND6\RCP-SIP-1.DOC
4

ATTACHMENT A

LEGALLY ENFORCEABLE MECHANISM (PERMIT)

TO ENSURE COMPLIANCE WITH

REASONABLY AVAILABLE CONTROL TECHNOLOGY REQUIREMENTS

FOR

Reynolds Consumer Products LLC – Bellwood Printing Plant

Chesterfield County, Virginia

Registration No. 50260

Under the authority provided in 9VAC5-170-180 and Section II of Agency Policy 

Statement No. 3-2006 (dated October 20, 2006), the Director of the Piedmont Regional 

Office approved and issued the permit on October 20, 2015, to be effective that same 

day. The permit was approved and issued following the procedural requirements of 

Virginia's federally enforceable state operating permit program, Article 5 (9VAC5-80-

800 et seq.) of Part II of 9VAC5-80 (Permits for Stationary Sources).
Molly Joseph Ward 

Secretary of Natura! Resources 

COMMONWEALTH of VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

PIEDMONT REGIONAL OFFICE 

4949-A Cox Road, Glen Allen, Virginia 23060 

(804) 527-5020 Fax (804) 527-5106 

'NWW .deq. virginia.gov 

STATIONARY SOURCE PERMIT TO OPERATE 

David K. Paylor 

Director 

Michael P. Murphy 

Regional Director 

This permit implements the requirements for Reasonably Available Control Technology (RACT) for 

Volatile Organic Compounds (VOC) in the Richmond, Virginia Emissions Control Area. 

This pennit (i) is for the purpose of implementing the "reasonably available control technology" (RACT) 

requirements of9 VAC 5-40-7390 ofthe Regulations of the Board and (ii) establishes control technology and 

other requirements for the control of volatile organic compound (VOC) emissions from the Reynolds Consumer 

Products LLC- Bellwood Printing Plant in the Richmond, Virginia Ozone Maintenance Area. These RACT 

requirements shall be the legal and regulatory basis for control ofVOC emissions from this facility. This pennit 

shall be effective upon approval by the U. S. Environmental Protection Agency following the requirements of 40 

CFR Part 51 (Requirements for Preparation, Adoption, and Submittal of Implementation Plans) and upon such 

approval this permit shall supersede your consent order dated October 31, 1986. 

In compliance with the Federal Clean Air Act and the Commonwealth of Virginia Regulations for the 

Control and Abatement of Air Pollution, 

is authorized to operate 

located at 

Reynolds Consumer Products LLC 

Bellwood Printing Plant 

2001 Reymet Road 

Richmond, VA 23237 

Registration No.: 50260 

a printing facility 

2001 Reymet Road 

Chesterfield County, Virginia 

in accordance with the Conditions of this pennit. 

Approved on October 20, 2015. 

Permit consists of 5 pages. 

Pe1mit Conditions 1 to 15. 

Air Permit Manager 
Reynolds Consumer Products LLC 

Bellwood Printing Plant 

50260 

October 20, 2015 

Page 2 

INTRODUCTION 

This pennit approval is based on the permit application dated August 13, 2015, and supplemental 

information dated August 27, 2015. Any changes in the permit application specifications or any existing 

facilities which alter the impact of the facility on air quality may require a permit. Failure to obtain such 

a permit prior to construction may result in enforcement action. 

Words or terms used in this permit shall have meanings as provided in 9 V AC 5-10-20 of the State Air 

Pollution Control Board Regulations for the Control and Abatement of Air Pollution. The regulatory 

reference or authority for each condition is listed in parentheses () after each condition. 

Annual requirements to fulfill legal obligations to maintain current stationary source emissions data will 

necessitate a prompt response by the permittee to requests by the DEQ or the Board for information to 

include, as appropriate: process and production data; changes in control equipment; and operating 

schedules. Such requests for information from the DEQ will either be in writing or by personal contact. 

The availability of information submitted to the DEQ or the Board will be governed by applicable 

provisions ofthe Freedom oflnformation Act,§§ 2.2-3700 through 2.2-3714 ofthe Code ofVirginia, 

§ 10.1-1314 (addressing information provided to the Board) of the Code of Virginia, and 9 V AC 5-170-

60 of the State Air Pollution Control Board Regulations. Information provided to federal officials is 

subject to appropriate federal law and regulations governing confidentiality of such information. 

Group A Facilities 

The Group A Facilities at the Plant* are: Presses Number 1, 2, 4, Extruders Number 1, 2. and 3, 

and the treating station for Press Number 3. ** 

Unit ID Equipment Description Rated 

Capacity 

21-1 Champlain Press 1 with a 55 inch max. web width for film, foil and 850ft/min 

paper (1975) 

21-2 Champlain Press 2 for film, foil and paper (pre-197 5) 800ft/min 

21-3 Champlain Press 3 (treating station only) N/A 

21-4 Champlain Press 4 for film, foil and paper (pre-197 5) 710ft/min 

21-10 Egan Extruder 1 for film, foil and paper (pre-1975) 1,010 ft/min 

21-11 Dilts/Egan Tandem Extruder 2 for film, foil and paper (pre-1975) 1,025 ft/min 

21-12 Dilts/Egan Tandem Extruder 3 for film, foil and paper (pre-1975) 1, 000 ft/min 

Additional Equipment 

24 Intra Roto Laminator 3 for film, foil and paper (pre-197 5) 1,000 ft/min 

Specifications included in the above tables are for informational purposes only and do not form 

enforceable terms or conditions of the permit. 

* "Plant" refers to Reynolds Consumer Products LLC (- Bellwood Printing Plant) in Chesterfield 

County. 

**The following equipment referenced in the Consent Order and Agreement dated October 31, 1986 

has been dismantled and removed from the Plant: Presses 6, 8, 9, 10 and 11, and Extruder 4. 
PROCESS REQUIREMENTS - VOC Emission Controls 

Reynolds Consumer Products LLC 

Bellwood Printing Plant 

50260 

October 20,2015 

Page 3 

1. Emission Controls -Volatile Organic Compound emissions from the affected facilities at the Plant 

shall be controlled and reduced as outlined in this permit. 

(9 V AC 5-40-7370 and 9 V AC 5-80-850) 

2. Emission Controls The ''Group A facilities" at the Plant are: Presses Number 1, 2, and 4, 

Extruders Number 1, 2, and 3, and the treating station for Press Number 3. 

(9 VAC 5-40-7370 and 9 V AC 5-80-850) 

3. Control Efficiency - The reduction in Volatile Organic Compound emissions from the Group A 

facilities at the Plant shall not be less than sixty-five (65) percent, by weight on a daily basis over the 

historical amount of solvent used to apply the same amount of solids. Across line averaging of 

emission reductions will be utilized to determine compliance with the specified daily emission 

reduction requirement. 

(9 VAC 5-40-7370 and 9 VAC 5-80-850) 

4. Monitoring- Compliance with the requirements of Conditions 2 and 3 for the Group A facilities 

will be determined by the use of a "Daily VOC Model". The model will calculate daily emission 

reductions by comparing actual material usings to the historical amount of solvent bearing material 

used. The model will calculate daily emissions by measuring, on a job basis, all VOC bearing 

materials consumed. Total job VOC usings shall be apportioned to individual days based on 

production records. The daily historical amount of solvent which would have been used shall be 

calculated by factors relating the daily amount of applied solids and the historical amount of solvent 

required to apply a pound of solids. The historical factors and compliance calculations are shown in 

Attachment A. 

(9 V AC 5-40-73 70 and 9 V AC 5-80-850) 

EMISSIONS LIMITATIONS 

5. Process Emission Limits- The Board has determined that RACT for No.3 Laminator is an 

emission limit of2.0 tons per day. Attachment B to this permit outlines the basis for this 

determination. 

(9 V AC 5-40-7370 and 9 VAC 5-80-850) 

RECORDS 

6. On Site Records - The permittee shall maintain records of emission data and operating parameters 

as necessary to demonstrate compliance with this permit. The content and format of such records 

shall be arranged with the Piedmont Regional Office. These records shall include, but are not 

limited to: 

Records consisting of information as to the calculated daily reduction in emissions of Volatile 

Organic Compounds from the Group A facilities, except those emissions treated by add-on 

control equipment at the Plant. 
Reynolds Consumer Products LLC 

Bellwood Printing Plant 

50260 

October 20, 2015 

Page4 

These records shall be available for inspection by the DEQ and shall be current for the most recent 

two years. 

(9 V AC 5-40-7370 and 9 VAC 5-80-850) 

NOTIFICATIONS 

7. Exception Reports- Reynolds Consumer Products LLC shall provide the Board an exception 

report at the end of any quarter when conditions 1, 2, or 3 of this permit are not met. 

(9 V AC 5-80-850) 

TESTING 

8. Emission Testing- The printing facility shall be constructed so as to allow for emissions testing 

upon reasonable notice at any time, using appropriate methods. Sampling ports shall be provided 

when requested at the appropriate locations, and safe sampling platforms and access shall be 

provided. 

(9 V AC 5-80-880 and 9 V AC 5-80-850) 

GENERAL CONDITIONS 

9. Relationship to Other Permit Requirements- Except to the extent that conditions in this permit 

may be more stringent, this permit does not supersede or replace any other valid permit, or any other 

regulatory or statutory requirement. Furthermore, this approval to operate shall not relieve Reynolds 

Consumer Products LLC of the responsibility to comply with all other local, state and federal 

regulations, including permit regulations. 

(9 V AC 5-80-800 D and 9 V AC 5-80-820 F) 

10. Federal Enforceability- Once this permit is approved by the U.S. Environmental Protection 

Agency into the Commonwealth of Virginia State Implementation Plan, the permit is enforceable by 

EPA and citizens under the federal Clean Air Act. 

(9 V AC 5-80-800 C.2 and 9 V AC -5-80-820 F) 

11. Permit Modification- The Board may revise (modifY, rev..rrite, change or amend) or repeal this 

permit with the consent of Reynolds Consumer Products LLC, for good cause shown by Reynolds 

Consumer Products LLC, or on its own motion provided approval of the revision or repeal is 

accomplished in accordance with the Regulations of the Board and the Administrative Process Act 

(§2.2-4000 et seq.). Such revision or repeal shall not be effective until the revision or repeal is 

approved by the U.S. Environmental Protection Agency following the requirements of 40 CFR Part 

51 (Requirements for Preparation, Adoption, and Submittal ofimplementation Plans). 

(9 V AC 5-80-960 and 5-80-1 000) 

12. Failure to Comply- Failure by Reynolds Consumer Products LLC to comply with any of the 

conditions of this permit shall constitute a violation of a Permit of the Board. Failure to comply may 

result in a Notice of Violation and civil penalty. Nothing herein shall waive the initiation of 

appropriate enforcement actions or the issuance of orders as appropriate by the Board as a result of 
Reynolds Consumer Products LLC 

Bellwood Printing Plant 

50260 

October 20, 2015 

Page 5 

such violations. Nothing herein shall affect appropriate enforcement actions by any other federal, 

state, or local regulatory authority. 

(9 VAC 5-80-820 F, 9 V AC 5-80-910, and 9 V AC 5-80-101 0) 

13. Right of Entry - The permittee shall allow authorized local, state, and federal representatives, upon 

the presentation of credentials: 

a. To enter upon the permittee's premises on which the facility is located or in which any records 

are required to be kept under the terms and conditions of this permit; 

b. To have access to and copy at reasonable times any records required to be kept under the terms 

and conditions of this permit or the State Air Pollution Control Board Regulations; 

c. To inspect at reasonable times any facility, equipment, or process subject to the terms and 

conditions of this permit or the State Air Pollution Control Board Regulations; and 

d. To sample or test at reasonable times. 

For purposes of this condition, the time for inspection shall be deemed reasonable during regular 

business hours or whenever the facility is in operation. Nothing contained herein shall make an 

inspection time unreasonable during an emergency. 

(9 V AC 5-170-130 and 9 V AC 5-80-850) 

14. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new owner 

shall abide by any current permit issued to the previous owner. The new owner shall notify the 

Piedmont Regional Office of the change of ownership within 30 days of the transfer. 

(9 V AC 5-80-940) 

15. Permit Copy - The permittee shall keep a copy of this permit on the premises of the facility to 

which it applies. 

(9 V AC 5-80-860 D) 
COMMONWEALTH of VIRGINIA

DEPARTMENT OF ENVIRONMENTAL QUALITY

PIEDMONT REGIONAL OFFICE

MEMO

TO: File

FROM: Cheryl Mayo, Environmental Specialist II

DATE: September 2, 2015

SUBJECT: Engineering Analysis Memo

Company Name:

Bellwood Printing Plant

Reynolds Consumer Products LLC

2001 Reymet Road

Richmond (Chesterfield County), Virginia 23237

Reynolds Consumer Products LLC – Bellwood Printing Plant has requested a State Operating 

Permit as a mechanism to enforce its RACT agreement after discovering typographical errors in 

Attachment A to its current Consent Agreement and Order (DSE-413A-86), dated October 31, 

1986. The permit fee of $7349 was received on August 19, 2015, and the application was 

complete on August 27, 2015. 

The facility is required to use a “Daily VOC Model” (Condition E.5. of the Consent Order) to 

demonstrate a 65% daily VOC emissions reduction for its “Group A” facilities. The definitions 

for the model are found in Attachment A to the consent order. The errors are found in the 

definitions for X14 and X15.

The current definitions for X14 and X15 are:

X14 =X14+X5+X6+X7+X8+X9+X10+X11+X12+X13, and

X15 = X14+X0+X1+X2+X3 - X14 - X5 - X6 - X7

These should, instead, be changed to:

X14 =X4+X5+X6+X7+X8+X9+X10+X11+X12+X13, and

X15 = X14+X0+X1+X2+X3 - X4 - X5 - X6 - X7
Engineering Analysis Memo

Reynolds Consumer Products LLC

50260

Page 2

Since the Consent Agreement and Order (DSE-413A-86) has already been incorporated into 

the State Implementation Plan, the issuance of a State Operating Permit is being used as an 

alternative to revising the SIP. No emissions or operational changes are occurring at the plant—

the change is administrative due to typographical errors. Public notice for the permit is being 

published in Style Weekly magazine from September 16, 2015 to October 19, 2015 in 

accordance with 9 VAC 5-80-1020. EPA Region III will be sent a copy of the State Operating 

Permit once it is issued.

The permit incorporates only the conditions of the consent order (Conditions 1 – 7), along with

general permit conditions relating to testing, right of entry, change of ownership, etc. All 

operational requirements are limited in scope to those required by the consent order.

Since the Consent Order and Agreement was issued in 1986, several of the Presses (Numbers 

6, 8, 9, 10 and 11) and Extruder Number 4 have been dismantled and removed. This is noted in 

the Introduction to the permit. A corrected Attachment A and Attachment B (the original RACT 

analysis referenced in the Consent Order and SOP) are also attached.
Rl 

R2 

R3 

R4 

xo 

Xl 

X2 

X3 

X4 

xs 

X6 

X7 

X8 

X9 

XJO 

Xll 

X12 

Xl3 

X14 

XIS 

X16 

X17 

Emission Calculations Formulas 

to Calculate Estimated Percent Reduction ofVOC 

Bellwood Printing Plant 

Registration No. 50260 

4.3093 

5.7709 

92.1007 

12.0523 

Constant based on two year solvent/solid ratio for solvent inks 

Constant based on two year solvent/solid ratio for solvent 0/C* 

Constant based on two year solvent/solid ratio for solvent treating 

Constant based on two year solvent/solid ratio for solvent thermos and H/S* 

Calculated solvents replaced by WB* inks 

Calculated solvents replaced by WB 0/C 

Calculated solvents replaced by WB treating 

Calculated solvents replaced by WB thermos 

Total actual solvent (alcohol) content in WB inks 

Total actual solvent (alcohol) content in WB 0/C 

Total actual solvent (alcohol) content in WB treats 

Total actual solvent (alcohol) content in WB thermos and H/S 

Total actual solvent content in solvent inks 

Total actual solvent content in solvent 0/C 

Total actual solvent content in solvent treat 

Total actual solvent content in solvent thermos and H/S 

Total actual solvent (alcohol) content in M numbers* 

Total pounds of raw solvent used 

Total actual solvent usage for time period 

Total estimated solvents the plant is capable of using ifWB 

Materials were not used 

Total pounds reduction 

Percent reduction 

(Rl X #Solids in WB inks) 

(R2 X # Solids in WB 0/C) 

(R3 X #Solids in WB treating) 

(R4 X # Solids in WB thermos and H/S) 

Actual 

Actual 

Actual 

Actual 

Actual 

Actual 

Actual 

Actual 

Actual 

Actual 

X4+X5+X6+X7+X8+X9+XlO+Xll+Xl2+X13 

X14+XO+XI+X2+X3-X4-X5-X6-X7 

XIS X14 

((X15 -X14)/X15 X 100) 

* 0/C - Overcoat 

H/S - Heatseal 

WB- Waterbase 

M Numbers- Reynolds internal code to identify materials 

ATTACHMENT A 
REYNOLDS ALUMINUM 

Reynolcs Memi5. Ccincany vocprua23261 

June 23, 1986 

Mr. Paul L. Pitts 

Commonwealth of Virginia 

State Air Pollution Control Board 

Ninth Street Office Building 

Richmond, Virginia 23219 

AT TACTHM ENT B 

RE: Reynolds Metals Company 

Dear Mr. Pitts: 

Richmond Area Graphic Arts 

Program 

Please find attached a source specific RACT analysis for 

Laminator No. 3 at the Bellwood Printing Plant. We believe this 

analysis supports a determination that an annual emission limit 

of 203 tons per year constitutes RACT for Laminator No. 3. 

We stand ready to meet with the State Air Pollution Control Board 

staff to further discuss this 

issue. Please feel free to 

contact Mr. K. N. Weiss or 

me. 

LCT.stt 

Attachments 

cc: J. M. Daniel K. N. Weiss 

Lawrence C. 

Director, En ' 

Environmental C 

a, Jr., P.E. 

ental Control 

trol Department 
1. -Introduction 

REYNOLDS METALS COMPANY 

Bellwood Printing Plant 

Laminator No. 3 

Source Specific RACT Analysis 

Laminator No. 3 (the "Laminator") at the Bellwood Printing Plant 

lS a unique piece of production equipment which is 

substantially different from the packaging rotogravure printing 

equipment used at most graphic arts plants. The Laminator is 

characterized by its ability to process heavy gauge metal 

(greater than .001 inches) and, consequently, it is necessary 

that its drying ovens use an uniquely large oven air flow. The 

large oven air flow and the uniqueness of this specific 

production process would make the installation of air pollution control 

devices on the Laminator extremely expensive, relatively 

inefficient, and, in our opinion, unreasonable. 

For these reasons,this piece of equipment does not fit the 

"presumptive norm" by which EPA has defined "Reasonably Available 

Control Technology" ("RACT") for the rotogravure printing process 

at graphic arts plants. To a large extent, EPA's "presumptive norm" is 

based on the cost-effectiveness of reducing VOC emissions from 

the graphic arts process. 
This document will demonstrate that the cost of VOC emission 

control on the Laminator (using add-on technology such as an 

incineration) far exceeds the reasonable cost of emission 

reduction that represents the 44 presumptive norm" for RACT at 

graphic arts plants and other web coating type facilities. In 

other words, the cost of reducing VOC emissions from the 

Laminator is well above the cost EPA has considered reasonable in 

defining RACT for graphic arts and other source categories. 

Accordingly, we are requesting that RACT for the Laminator be 

defined as an annual emission limit of 203 tons per year. 

The Laminator is utilized to produce unique products at the 

Bellwood Printing Plant. It is the only laminator at the Plant 

which has the capability to produce film/foil laminations 

consisting of unusually heavy substrates. This unique ability 

results from the Laminator's special oven design. 

The top oven on the Laminator is a four zone oven. The 

entry to the oven is zone 1 and the oven exit is zone 4. The 

zone 2 exhaust is delivered to zone 1, thus placing the oven 

entrance under slight positive pressure. 

The bottom oven on the Laminator is a flotation system oven. 

The film/foil substrate actually floats through the oven on an 

air bed. The high exhaust rate necessary to float the substrate 
causes the entire oven to be under positive pressure thus making 

fume capture very difficult. The flotation system oven, however, 

provides Laminator 3 with its unique ability to process heavy 

gauge metal film/foil laminations. Heavy gauge metal tends to 

wrinkle when passing over idlers in non-flotation systems. The 

fact that the metal doesnot touch any surlacein the bottom oven 

prevents wrinkles from occurring. The heavy gauge substrate also 

acts as a heat sink, thus requiring either high volumes of drying 

air or high temperatures to cure inks, coatings or adhesives. 

However, the film portion of the substrate cannot withstand high 

temperatures, therefore, a high volume of air is necessary to 

properly dry or cure the web. 

The total air flow for the Laminator is approximately 40,000 

scfm as compared to 6,000. scfm for a "typical" laminator not 

producing the unique products the Laminator produces. 

III. RACT and the Presumptive Norm 

RACT is defined as "the lowest emission limitation a 

particular source is capable of meeting by the application of 

control technology which is reasonably available considering 

technological and economic feasibility" (highlighting added) . As 

such, the economic feasibility, or the cost-effectiveness of 

installing and operating certain control devices, is a 

fundamental factor which must be considered in determining 

RACT for a specific source. 
4 

In 1979, EPA announced (FR, Vol 44, No. 181, at p. 53762, 

53763) that each Control Technique Guideline ("CTG") contains 

reconTrYLendations to the states of what EPA calls the "presumptive 

norm" for RACT. EPA's announcement continues by stating that the 

states are free to vary from the "presumptive norms" to take into 

account "unique circumstances". EPA also notes that "The States 

may develop case-by-case RACT requirements independently of EPA's 

recommendation. EPA will propose to approve any submitted RACT 

requirement that the State shows will satisfy the requirements of 

the Act for RACT, based on the economic and technical 

circumstances of the particular sources being regulated" (44 FR 

at 53763) . 

On April 11, 1986, Mr. Gerald A. Emison of EPA announced the 

following: "Where EPA cannot rely on presumptive norms, RACT for 

a particular source is determined on a case-by-case basis 

considering the technological and economic circumstances of the 

individual source. Hence, whether or not a source is addressed 

by a CTG, no universally applicable decision rule can supplant 

case-by-case -judgment on what constitutes RACT. 

In evaluating economic feasibility for RACT, the Agency 

gives significant weight to cost-effectiveness. However, no 

specific cost effectiveness threshold exists to determine RACT. 

Numerous other factors (i.e., age of facility, quantity of 

emission, nature of emission, severity of existing air quality 

problem, extent of controls present, comparability to standard 
5 

industry practice in related industries, cross media impacts, 

economic impacts, etc.) must be considered in establishing RACT. 

It is conceivable, given differing local circumstances, that a 

control option could be reasonably available in one location and 

unreasonable in another."· (highlighting added) . 

Quite clearly, EPA's latest guidance states that a caseby-case analysis of each piece of control equipment to 

determine RACT is preferred over the arbitrary application of 

CTG recommendations. Additionally, cost-effectiveness should 

clearly be given signi cant weight in evaluating the 

economic feasibility for RACT .. 

As illustrated in the sections which follow, the Laminator 

is a unique piece of production equipment and the cost of 

installing incineration equipment would substantially exceed the 

presumptive norm cost for graphic arts or many other similar web 

coating categories studied by EPA. This document clearly shows 

that the economic feasibility criteria of RACT precludes a 

requirement for the addition of add-on control equipment on the 

Laminator. Further, EPA's own guidance clearly provide for 

situations like this where the EPA recommended "presumptive 

norm" is inappropriate and source specific analyses would 

support a different definition of RACT (Id.). Additionally, the 

SAPCB regulations also specifically provide for the adoption of 

source specific RACT as requested in this submittal. (ex. 

Section 120-04-3604D) 
6 

IV. The Presumptive Norm for Graphic Arts 

In the CTG document entitled "Control of Volatile Organic 

Emissions from Existing Stationary Sources--Volume VIII: Graphic 

Arts--Rotogravure and Flexography" (the "CTG"), EPA presented 

emission limits based on the capabilities and problems general to 

the industry. These limits known as the "presumptive norm" form 

the basis for the SIP requirements for rotogravure packaging 

plants. The SIP essentially requires a 65 percent control level 

for sources with greater than 100 tons per year of emissions. As 

shown in Figure 4.4 and 4.5 (attached), which are extracted from 

the CTG, at approximately the 100 tpy emission level, EPA 

expected the cost-effectiveness Of the "presumptive norm" (using 

incineration devices) to be approximately $2,000 per ton of VOC 

removed (in 1978 dollars). 

V. Capital and Operating Costs of Incineration 

The formal "Engineers Estimate" for installing an 

incinerator on the Laminator is attached. As shown in the 

estimate, Reynolds estimates that the capital cost of the 

incinerator would be $1,890,000. Based on Bellwood Printing 

Plant's experience with other incinerators, the Company believes 

that operating costs for the incinerator would be approximately 

$225,000 per year. 
VI. Cost Effectiveness of VOC Control on the Laminator 

The positive pressure system ovens of the Laminator 

makes fume capture very difficult and separates this piece of 

equipment from EPA's "presumptive norm". 

Based on the unique oven configuration of the Laminator, 

Reynolds estimates that fume capture efficiency for the Laminator 

would be approximately 50 percent. The Laminator has annual 

projected emissions of 203 tons per year and an incinerator would 

be expected to destroy 90 percent of the VOC delivered to the 

unit.ml Thus, if an incinerator were added, and the Laminator was 

operating at full capacity, it would potentially abate 91.35 tons 

per year of VOC. 

The total capital cost of the incinerator may be annualized 

by using a Capital Recovery Factor (CRF) . 

CRF l + i I ( ( 1 + i) n -1 ) 

(A)This analysis is focused on the addition of incineration 

equipment. The same conclusions would apply if the cost of carbon 

adsorption equipment was utilized. Also, although Reynolds 

continues to study low solvent technology, it should be 

recognized that low solvent technology is not presently 

commercially available for the products produced on this piece of 

equipment. 
Assuming a 10 year life for the incinerator and 1=12 percent, 

the CRF equals 17.70% and the annualized capital charge would 

equal ( . 1 7 7 0 ) ( $1 , 8 9 0 , 0 0 0 ) or $ 3 3 4 , 53 0 . 

Thus, the annualized incinerator cost would be $334,530 for 

capital cost plus $225,000 for operating costs for a total cost 

of about $559,000. 

The incinerator would potentially abate 91.35 tons per year 

of VOC. Thus, the cost-effectiveness of VOC control by 

incineration for the Laminator is $559,000/91.35 or $6125/ton. 

VII. Comparison to the Presumptive Norm for Graphic Arts 

Clearly, the cost of adding incineration equipment on the 

Laminator grossly exceeds the cost of EPA's "preswnptive norm" or 

cost-effectiveness gauge and, in our opinion, it would not be 

reasonable, nor would it constitute RACT. The cost-effectiveness 

of incineration for the Laminator is $6,125 per ton of VOC 

abated. The EPA presumptive norm cost-effectiveness rr~asure, even 

adjusted for inflation, is still only $3,137, based on the cost 

index in the 9th annual edition of Means Mechanical Cost Data. 

Accordingly, as stated above, incineration of emissions from the 

Laminator would be nearly twice the EPA presumptive norm cost 

and, quite clearly, would be unreasonable and well beyond 

recommended RACT. 
VIII. Comparison to Mr. G. A. Emison of EPA's Guidance of 

April 11, 1986 

The type of analysis presented in this document is exactly 

the type of case-by-case 1.view to determine RACT which is 

advocated in Mr. Emison's guidance. Additionally, the 

technological problems in fume capture, which separates this 

source from the type of CTG source studied by EPA, are taken into 

account in this analyses. 

The economic feasibility criterion of RACT, in regards 

to the cost-effectiveness of control on the Laminator, is 

well discussed in this document. 

Other factors referenced in Mr. Emison's guidance include: 

1. Age of Facility - The Laminator is an aged piece of 

equipment which is some 18 years old. 

2. Severity of Air Quality Problem- The Richmond area has 

experienced two consecutive years of meeting the ozone 

ambient air quality standard. If this year follows the 

trend of the past, the Richmond area can be 

reclassified to attainment status next year. In any 

event, the ozone air quality situation in the Richmond 

area is not "severe". 
10 -

3. Comparability to Standard Industry Practice - As 

illustrated in this document, the Laminator is a unique 

piece of equipment which does not fit the "presumptive 

norm". 

4. Cross Media Impacts - There would be no adverse 

cross media impacts. 

In summary, Reynolds has performed the type of analysis 

envisioned by the Emison guidance. The analysis supports the 

conclusion that an annual emission limit of 203 tons per year 

constitutes RACT for the Laminator. 

IX. Comparison to Other EPA RACT Determinations 

In developing RACT recommendations for other source 

categories, EPA has established cost-effectiveness values 

for a number of web source categories as shown below: 

SOURCE 

Coil Coatinq 

(Operating Costs Only) 

Fabric Coating 

Carbon Adsorption 

Incineration 

Paper Coating 

Carbon Adsorption 

Incineration 

RACT Cost 

$/Ton VOC Removed 

( 197 7 dollars) 

44 - 153 

157 - 721 

13 - 54 

50 - 125 

13 - 51 
The above figures represent the presumptive norm costs for 

RACT on other source categories. These figures are all well 

Within $1,120 per ton of VOC removed when adjusted to 1986 

dollars. Thus, the cost of incineration on the Laminator would 

be about five times as expensive as the costs EPA has expected 

other source owners to spend. In our view, the incineration of 

emissions from the Laminator would clearly exceed the RACT cost 

levels experienced in other industries. 

X. Comparison to EPA Region III Guidance Report 

In 1984, U.S. Environmental Protection Agency Region III 

representatives gave the State Air Pollution Control Board and 

Reynolds a copy of a document entitled "Determination of Plant--

Specific RACT for the Paper and Fabric Coating Industries in 

Massachusetts." EPA noted that this document would be a good 

guide for Reynolds to use. In this document it is stated that, 

"The consensus reached among the TRC engineering team was that 

costs in excess of $2500/ton VOC controlled would constitute an 

unacceptably poor cost-effectiveness." It is our understanding 

that this report provided the basis for RACT determinations ln 

EPA Region II for the referenced sources. Adjusted to 1986 

dollars, the cost-effectiveness criterion used in this 

recommended EPA Region III guide would be $3,236/ton VOC 

controlled. 
12 

As previously stated, it would cost $6,125 per ton of VOC 

removed to add incineration at the Laminator. When compared to 

the EPA Region III recommended guide of $3,236 per ton VOC 

controlled, it is once again clear that incineration of 

emissions from the Laminator would not be cost-effective and 

would not represent RACT as determined for other VOC sources. 

XI. Other Source fie RACT Determinations in 

In 1985, the SAPCB approved a source specific RACT for 

another Richmond area source. The projected cost-effectiveness 

value for adding incineration equipment on the Laminator exceeds 

the value approved for this other source. 

XII. Conclusion on Source-Speci c RACT Determination for 

the Laminator 

Due to the unique nature of the Laminator and since no low 

solvent technology currently exists for the Laminator, Reynolds 

Metals Company believes that RACT for the Laminator should be 

defined as an annual emission limit of 203 tons per year. We 

believe that we have documented that incineration would be 

unreasonably expensive and exceed RACT. Reynolds is, however, 

continuing research and development of low solvent technology for 

the Laminator and is willing to provide the SAPCB with periodic 

reports on the status of low solvent technology for the 

Laminator. 
_l_L 

. EMISSIONS AT 500 ppm YU . 

o EMISSIONS AT 1500 ppm 'ME 

6 

Lo 

4 CJr\Tiffi 

1 

200 300 400 .... 500 1500 100 

(110) (220) (330) (440) (550) (1650) 

ANNUAL PLANT INK USAGE. Mg/yr (too/yr) 

Figure 4-4. Cost-effectiveness of thermal incineration• without heat 

recovery for VOC control of rotogravure printing process 

at graphic arts plant. 

4-22 

1 

2500 

(2750) 
li ~ 

!2 -.::> 

""' "' .., 

'-

... 

c: 

"" lf) ~ 

..... 

c: 

"" 

~ ..., 

;:> 

0 

0,. 

~ .._ . EMISSIONS AT 500 ppm VOC 

0 EMISSIONS AT 1500 PM VOC 

l Vl 

L 

«l j r-

'0 b -o 

-o 

;a 

·~ Vl 

::> 

0 

..<::: 

+-' 

00 

1'--

(j) 

r-l 

vi' 

tD 

~ w L LL 

LL 

w 

I ! § ~ 

,...•;j --- u 

! 

! ;tt~ ~J L~- ______ L__ ___ ~7a ---o --~---· 

100 200 300 400 500 1500 2500 

(110) (220) (330) (440) (550) (1650) (2750) 

ANNUAL PLANT INK USAGE. Mg/yr (ton/yr) 

Figure 4-5. cost-effectiveness of thermal incineration control with 

40 percent heat recovery for voc of rotogravure printing 

process at graphic arts plant. 

4-23 
"IIRII=r:T 

114-1129-41 VIES PORN IS RRIXTED 01 Xi( DUPLICANR A 10 CAP. BE USED AS A MASTER FOR 23 COPIES OR LESS. 

PLANT 

t:COUNT 

NO. 

Bellwood Printing 

DATE __lune 16. 1986 

ENGINEERS ESTIMATE 

ESTIMATE NO -------

(EQUIPMENT, MATERIAL, AND LABOR FOR INSTALLATION REQUIREDI 

7515 

DEPARTMENT----------------------

DESCRIPTION DUANTTTY uNIT COST ITEM COST 

1.0 Site Preparation and Improvements 

2.0 

3.0 

4.0 

5.0 

6.0 

7.0 

8.0 

9.0 

0.0 

1.0 

Buildings 

Modifications to Existing Buildings 

Special Enclosures 

Structural Steel (Other Than Building) 

Foundations 

Mechanical Equipment Acquisition 

Mechanical Installation 

8.1 Labor 

8.2 Material 

Piping (Process & Machinery) 

9.1 Piping' 

9.2 Insulation 

Electrical Equipment Acquisition 

Electrical Installation 

60,000 

60,000 

15,000 

25,000 

25,01 

50,0C 

10,00 

1,090,00 

120,00 

40,00 

50,00 

50,00 
14.41,44 rEIS FORM IS PRINTED OW 0711 DUPLICATOR AND CAN BE USED AS A MASTER FOR 26 COPIES OR LESS. 

ENGINEERS ESTIMATE 

!EQUIPMENT, MATERIAL, AND LABOR FOR INSTALLATION REQUIRED) 

4UBJECT INCINERATOR FOR NO. 3 LAMINATOR 

PLANT _____ B __ e_l_l_w_o_o_d ___ P_r_i_n_t __ i_n_3 __________________ __ 

.CCOUNT 

ND. 

12.0 

13.0 

114.0 

15.0 

. 6.0 

7.0 

18.0 

3.0 

lLo 

2.0 

DESCRIPTION 

Pollution Control Equipment (Air, Water, Noise 

Modification to Existing Equipment 

Material Handling Equipment 

Fuel Storage and Distribution Systems 

Fare Protection Equipment 

OfficeFurniture and Equipment 

Unclassified 

Freight 

Engineering @ 10% 

Contingency @ 10% 

Project to be completed 15 months after approval .. 

Project will be closed 18 months after approval of pro e 

W. A. Via, Printing Unit Engineering Manager 

PAGE MO 

DATE-Lunell. 1986 

ESTIMATE MO 

DEPARTMENT _________________ 7_,5~ ___ 1=-~5 

QUANTITY UNIT COST ITEM COS 

130 

10,1 

158, c 

l 'i8 ( 

1 $L89L1 
***OCR*** 

The following pages contain the Optical Character Recognition 

text of the preceding scanned images. 
DSE-413A-86 

ELIZABETH H HASKELL. CHAIRMAN 

MARTINSVILLE Amonded 10/86 

CARL C. RECINGER. VICE CHAIRMAN 

ALEXANDRIA 

TIMOTHY E BARROW %C4'. 17'MMOWWEA LTH of VIRCjiNIA 

VIRGINIA BEACH 

MANUEL DEESE State Air Pollution Control Board R:CHARD L. CODY 

RICHMOND EXECUTIVE DIREC I OR 

ROOM 801. WNTH STREEI OFFICE 3 JILDING 

POST OFFICE 60. 10089 

WALLACE E REED RICHMOND. VIRCjiNIA @3240 

CHARLOTTESVILLE ?6C.31 1186 2378 

STATE IMPLEMENTATION PLAN 

CONSENT AGREEMENT AND ORDER 

ADDRESSING 

REYNOLDS METALS COMPANY'S 

BELLWOOD PRINTING PLANT 

REGISTRATION NO. 50260 

SECTION A: Purpose 

This Order is a reissuance of the Order designated DSE-413-86. It is issued 

to allow the Reynolds Metals Company, Bellwood Printing Plant to operate the 
affected facilities at the Plant with controls equivalent to those contained i 

n 

Virginia's federally approved State Implementation Plan. 

SECTION B: References 

Unless Lhe context indicates otherwise, the following words and terms have 

the meanings assigned to Lhem below: 

1. "Code" means the Code of Virginia (1950), as amended. 

2. "BOARD" or "SAPCB" means the State Air Pollution Control Board, an 

agency of the Commonwealth of Virginia created pursuant to 

10-17.11 of the Code. Particular powers and duties of the Board 

are referred to in Section C of this document. 

3. "Order" means this Consent Agreement and Order. 

4. "SAPCB Regulations" means the State Air Pollution Control Board's 

Regulations for the Control and Abatement of Air Pollution, 

5. "Bellwood Plant" or the "Plant", refers to Reynolds Metals Company's 

Bellwood Printing Plant in Chesterfield County. 

6. "Bally" means the 24-hour time period beginning at 11:00 p.m. 
Order With Reynolds Bellwood Plant 

Registration No. 50260 

7. "Reynolds Metals Company" or "Reynolds" refers to Reynolds Metals 

Company, 6601 West Broad Street, Richmond, VA 23261. 

8. "RACT" refers to Reasonably Available Control Technology. 

SECTION C: Authority 

1. Chapter 1.2 of Title 10 of the Code of Virginia (1950), as 

amended (Code), creates the Board and vests in it the authority to 

supervise and control various aspects of air pollution in the 

Commonwealth. Among the g@ants of power to the Board is included the 

authority to promulgate regulations "'abating, controlling and 

prohibiting" air pollution.found.ed in 10-17.18(b). 

2. Pursuant to its authority, the Board has promulgated regulations 

entitled "Commonwealth of Virginia, State Air Pollution Control 

Board, Regulations for the Control and Abatement of Air 

Pollution." The "SAPCB Regulations" first took effect March 17, 

1972, with subsequent amendments. 

3. Pursuant to 10-17.18(d) and 10-17.18:1, the Board has the 

authority to issue orders to diminish or abate the causes of air 

pollution and to enforce its rules and regulations. Orders of the 

Board are enforceable pursuant to 10-17.23 of the Code. 

4. The Executive Director is the chief executive officer of the 

Board. Under Code 10-17.14, the Executive Director is authorized 

to supervise, administer and enforce the provisions of Chapter 1.2 

of Title 10 of the Code, as well as the rules, regulations, and 

orders of the Board. Additionally, the Executive Director shall 

have such powers as are conferred upon him by the Board. The SAPCB 

Regulations Appendix F contain the Delegation of Authority from 

the Board to the Executive Director. In paragraphs II (A) through 

(J) of Appendix.F the Executive Director is given the authority to 

act to abate or control air pollution, approve consent agreements 

and consent orders, and perform other duties as prescribed by law 

or regulation and, as required, to carry out the policies and 

directives of the Board. In paragraph II (L) of Appendix F the 

Assistant Executive Director for Operations is delegated the 

authority to act for the Executive Director when he is absent for 

three or more days. 

SECTION D: Findings 

1. On April 5, 1982 the BOARD approved a plan outlining a compliance 

program for the Bellwood Plant representing RACT and on December 14, 

1982 the BOARD and Reynolds entered into a Consent Agreement 

reflecting the Board approved plan. 

(2) 
Order With Reynolds Bellwood Plant 

Registration No. 50260 

2. Reynolds has fully complied vvi th the 1982 Agreement. 

3. On June 27, 1986 Reynolds and the Board entered into a revised 

Order. 

4. In order to resolve EPA questions, Reynolds has agreed to amend 

the previous orders and is agreeable to operating the affected 

facilities at the Bellwood Plant under an alternative compliance 

schedule to that contained in the Orders or Appendix N., Section 

III of the Regulations. 

5. The SAPCB Regulations, Section 120-04-3604 A, provide for the use 

of water-borne inks. 

6. The SAPCB Regulations, Section 120-04-3604 D, provide for the use 

of alternative compliance programs. 

7. The time granted by the BOARD has allowed Reynolds to develop its 

low solvent technology to the point where Reynolds can now improve its 

control technology. 

8. Analysis and review by the BOARD of the emissions from the 

Bellwood Plant indicate that these emissions do not constitute a 

hazard to the health of the residents in the vicinity of the Plant, 

that the terms of this Order represent RACT for the affected 

facilities, and that the issuance of this Order will not interfere 

with but rather enhance the Board's strategy for attainment and 

maintenance of the ambient air quality standards. 

SECTION E: Apreement and Order 

Accordingly, the Board orders and Reynolds Metals Company agrees that: 

1. This Order supersedes all previous Agreements and Orders of the 

Board relative to the affected graphic arts facilities at the Plant 

with the exception of the companion Board Order DSE-414A-86. 

2. Volatile organic compound emissions from the affected facilities 

at the Plant shall be controlled and reduced as outlined in this 

Order. 

3. The "Group A Facilities" at the Plant are: Presses Number 1, 2, 

4, 6, 8, 9, 10 and 11. Extruders Number 1, 2, 3 4 and the 

treating station for Press No. 3. 

4 The reduction in volatile organic compound emissions from the 

Group A facilities at the Plant shall not be less than sixty-five 

(65) percent, by weight on a daily basis over the historical amount 

of solvent used to apply the same amount of solids. 

(3) 
Order With Reynolds Bellwood Plant 

Registration No. 50260 

Across line averaging of emission reductions will be utilized to 

determine compliance with the specified daily emission reduction 

requirement. 

5. Compliance with the requirements of Condition 3 and 4 for the 

Group A facilities will be determined by the use of a "Daily VOC 

Medel." The model will calculate daily emission reductions by 

comparing actual material usings to the historical amount of 

solvent bearing material used. The model will calculate daily 

emissions by measuring, on a job basis, all VOC bearing materials 

consumed. Total job VOC usings shall be apportioned to individual 

days based on producti%n records. The daily historical amount of 

solvent which would have been u@sed shall be calculated by factors 

relating the dai*ly amount of applied solids and the historical 

amount of solvent required to apply a pound of solids. The 

historical factors and compliance calculations are shown in 

Attachment A. 

6. Records consisting of information as to the calculated dally 

reduction in emissions of volatile organic compounds from the 

affected facilities, except those emissions treated by add-on 

control equipment at the Plant, shall be kept available at the 

plant for at least a two year time period. Reynolds shall provide 

the Board an exception report at the end of any quarter when the 

conditions of Section E, Condition 2, 3 and 4 of this Order (DSE4l3A-86) are not met. 

7. The Board has determined that RACT for Laminator No. 3 is 

an emission limit of 2.0 tons per day. Attachment B to this 

Order outlines the basis for this determination. 

8. The Board may modify, rewrite, or amend this Order for good 

cause shown by Reynolds or on its own motion, after notice and an 

opportunity for a bearing. 

9. So long as this Order remains in effect, Reynolds Metals 

Company waives the right to public hearing (pursuant to Code 10-

17.18:1) and to judicial review of any issue of fact or law 

contained herein. Nothing herein, however, shall be construed as a 

waiver of the right to a hearing or to judicial review of any action 

taken by the Board to enforce or modify this Order. 

10. Failure by Reynolds Metals Company to comply with any of the terms 

of this Order shall constitute a violation of an Order of the 

Board. Nothing herein shall waive the initiation of appropriate 

enforcement actions or the issuance of additional orders as 

appropriate by the Board as a result of such violations. 

11. Reynolds Metals Company declares it has received fair and due process under the Administrative Process Act, Title 9, Chapter 1.1:1, 

Section 9-6.14, as affected by 10-17 18:1. 

(4) 
Order With Reynolds Bellwood Plant 

Registration No. 50260 

12. This Order shall become effective upon execution by both parties 

and shall continue in effect until terminated by the Board. 

The foregoing Consent Agreement and Order has been executed on behalf of the 

STATE AIR POLLUTION CONTROL BOARD of the COMMONWEALTH OF VIRGINIA and on behalf 

of REYNOLDS METALS COMPANY, each by its duly authorized representatives 

or self, on the dates indicated below. 

STATE AIR POLLUTION CONTROL BOARD 

OF THE COMMONWEALTH OF VIRGINIA 

BY: 

Cdate) l@ic and L. Cook 

Exelutive Director 

REYNOLDS METALS COMPANY 

'Nul 

October 31, 1986 BY: 

(date) Rodney V. Hanneman 

Vice President 

Corporate Quality Assurance 

and Technology Operations 

(5) 
ATTACHMENT A to 

the SIP Order 

DSE-413A-86 

Emission Calculations Formulas 

to Calculate Estimated Percent Reduction of VOC 

Bellwood Printing Plant 

Registration No. 50260 

RI 4.3093 Constant based on two years solvent/solid ratio for solvent inks 

R2 5.7709 Constant based on two year solvent/solid ratio for solvent 0/C* 

R3 92.1007 Constant based on two year solvent/solid ratio for solvent treati 

ng 

R4 12.0523 Constant based on two year solvent/solid ratio for solvent thermo s and H/S* 

XO Calculated solvents replaced by WB* inks (RI X# Solids in WB inks) 

XI Calculated solvents replaced by WB 0/C = (R2 X# Solids in WB 0/C) 

X2 Calculated solvents replaced by WB treating (R3 X # Solids in WB treating 

X3 Calculated solvents replaced by WB thermos (R4 X# Solids in WB thermos a n d H/S) 

X4 = Total actual solvent Jalcohol) content in WB inks Actual 

X5 = Total actual solvent (alcohol) content in WB 0/C Actual 

X6 Total actual solvent (alcohol) content in WB treats Actual 

X7 = Total actual solvent (alcohol) content in WB thermos and H/S Actual 

XS = Total actual solvent content in solvent inks = Actual. 

= Actual 

X9 = Total actual solvent content in solvent 0/C 

X10 = Total actual solvent content in solvent treat = Actual 

X11 = Total actual solvent content in solvent thermos = Actual 

and H/S 

X12 

X13 

X14 

2+XI3 

Total actual solvent (alcohol) content in M numbers* Actual 

Total pounds of raw solvents used Actual 

Total actual solvent usage for time period X14+X5+X6+X7+X8+X9+X10+X11+Xl 

X15 Total estimated solvents the plant is capable of using if X14+XO+Xl+X2+X 

3-X14-X5-X6-X7 

WE materials were not used 

Xl6 Total pounds reduction X15 - X14 

X17 Percent Reduction UX15- X14)/XI5) X 100) 

0/C - Overcoat M Numbers - Reynolds interal code to identify materials 

H/S - Heatseal 

WB - Waterbase 

(6) 
ATTACIUI::NT 

REYNOLDS ALUMINUM 

Repolas Meials Comoany RolmonCi v-r(i.,- a @1261 

June 23, 1986 

Mr. Paul L. Pitts 

Commonwealth of Virginia 

State Air Pollution Control Beard 

Ninth Street Office Building 

Richmond, Virginia 23219 

RE: Reynolds Metals Company 

Richmond Area Graphic Arts 

Program 

Dear Mr. Pitts: 

Please find attached a source specific RACT analysis for 

Laminator No. 3 at the Bellwood Printing Plant. We believe this 

analysis supports a determination that an annual emission limit 

of 203 tons per year constitutes RACT for Laminator No. 3. 

We stand ready to meet with the State Air Pollution Control 

Board staff to further discuss this issue. Please feel free to 

contact Mr. K. N. Weiss or me. 

Lawrence C. a, Jr., P.E. 

Director, E ental Control 

Environment C trol Department 

LCT.stt 

Attachments 

cc: J. M. Daniel 

K. N. Weiss 
REYNOLDS METALS COMPANY 

Bellwood Print Plant 

Laminator No. 3 

Source Specific RACT Analysis 

l. Introduction 

Laminator No. 3 (the I'Laminatorll)@Iat the Bellwood Printing 

Plant is a unique piece of production equipment which is 

substantially different fron the packaging rotogravure printing 

equipment used at most graphic arts plants. The Laminator is 

characterized by its abil to process heavy gauge metal 

(greater than .001 inches) and, consequently, it is necessary 

that its drying ovens use an uniquely large oven air flow. The 

large oven air flow and the uniqueness of this specific 

production process would make the installation of air pollution 

control devices on the Laminator extremely expensive, relatively 

inefficient, and, in our opinion, unreasonable. 

For these reasons, this piece of equipment does not fit the 

"presumptive norm" by which EPA has defined "Reasonably Available 

Control Technology" (llRACTll) for the rotogravure printing process 

at graphic arts plants. To a large extent, EPA's "presumptive norm" 

is based on the cost-effectiveness of reducing VOC emissions from 

the graphic arts process. 
2 

This document will demonstrate that the cost of VOC emission 

control on the Laminator (using add-on technology such as an 

incineration) far exceeds the reasonable cost of emission 

reduction that represents the "presumptive norm" for RACT at 

graphic arts plants and other web coating type facilities. In 

other words, the cost of reducing VOC emissions from the 

Laminator is well above the cost EPA has considered reasonable in 

defining RACT for graphic arts and other source categories. 

Accordingly, we are requesting that RACT for the Laminator be 

defined as an annual emission limit of 203 tons per year. 

II. Laminator Description 

The Laminator is utilized to produce unique products at the 

Bellwood Printing Plant. It is the only laminator at the Plant 

which has the capability to produce film/foil laminations 

consisting of unusually heavy substrates. This unique ability 

results from the Laminator's special oven design. 

The top oven on the Laminator is a four zone oven. The entry 

to the oven is zone 1 and the oven exit is zone 4. The zone 2 

exhaust is delivered to zone 1, thus placing the oven 

entrance under slight positive pressure. 

The bottom oven on the Laminator is a flotation system oven. The 

film/foil substrate actually floats through the oven on an air 

bed. The high exhaust rate necessary to float the substrate 
causes the entire oven to be under positive pressure thus making 

fume capture very diff cult. The flotation system oven, however, 

provides Laminator 3 w th its unique ability to process heavy 

gauge metal film/foil aminations. Heavy gauge metal tends to 

wrinkle when passing over idlers in non-flotation systems. The 

fact that the metal does n9t touch any surface in the bottom oven 

prevents wrinkles from occurring. The heavy gauge substrate also 

acts as a heat sink, thus requiring either high volumes of drying 

air or high temperatures to cure inks, coatings or adhesives. 

However, the film portion of the substrate cannot withstand high 

temperatures, therefore, a high volume of air is necessary to 

properly dry or cure the web. 

The total air flow for the Laminator is approximately 40,000 

scfm as compared to 6,000 scfm for a "typical" laminator not 

producing the unique products the Laminator produces. 

III. RACT and the Presumptive No 

RACT is defined as "the lowest emission limitation a 

particular source is capable of meeting by the application of 

control technology which is reasonably available considering 

technological and economic feasibility" (highlighting added). As 

such, the economic feasibility, or the cost-effectiveness of 

installing and operating certain control devices, is a 

fundamental factor which must be considered in determining RACT 

for a specific source. 
4 

In 1979, EPA announced (FR, Vol 44, No. 181, at p. 53762, 

53763) that each Control Technique Guideline (llCTGll) contains 

recommendations to the states of what EPA calls the "presumptive 

norm" for RACT. EPA's announcement continues by stating that the 

states are free to vary from the "presumptive norms" to take into 

account "unique circumstances''. EPA also notes that "The States 

may develop case-by-case RACT requirements independently of EPA's 

recommendation. EPA will propose to approve any submitted RACT 

requirement that the State shows will satisfy the requirements of 

the Act for RACT, based on the economic and technical 

circumstances of the particular sources being regulated" (44 FR at 

53763). 

On April 11, 1986, Mr. Gerald A. Emison of EPA announced the 

following: "Where EPA cannot rely on presumptive norms, RACT for a 

particular source is determined on a case-by-case basis considering 

the technological and economic circumstances of the individual 

source. Hence, whether or not a source is addressed by a CTG, no 

universally applicable decision rule can supplant case-by-case 

judcrment on what constitutes RACT. 

In evaluating economic feasibility for RACT, the Agency 

gives significant weight to cost-effectiveness. However, no 

specific cost effectiveness threshold exists to determine RACT. 

Numerous other factors (i.e , age of facility, quantitj Of 

emission, nature of emission, severity of existing air quality 

problem, extent of controls present, comparability to standard 
industry practice in related industries, cross media impacts, 

economic impacts, etc.) must be considered in establi RACT. 

It is conceivable, given differing local circumstances, that a 

control option could be reasonably available in one location and 

unreasonable in another." %(highlighting added). 

Quite clearly, EPA's latest guidance states that a 

case-by-case analysis of each piece of control equipment to 

determine RACT is preferred over the arbitrary application of CTG 

recommercdations. Additionally, cost-effectiveness should clearly 

be given significant weight in evaluating the economic feasibility 

for RACT. 

As illustrated in the sections which follow, the Laminator is a 

unique piece of production equipment and the cost of installing 

incineration equipment would substantially exceed the 

presumptive norm cost for graphic arts or many other similar web 

coating categories studied by EPA. This document clearly shows 

that the economic feasibility criteria of RACT precludes a 

requirement for the addition of add-on control equipment on the 

Laminator. Further, EPA's own guidance clearly provide for 

situations like this where the EPA recommended "presumptive 

norm" is inappropriate and source specific analyses would 

support a different definition of RACT (Id.). Additionally, the 

SAPCB regulations also specifically provide for the adoption of 

source specific RACT as requested in this submittal. (ex. 

section 120-04-36040) 
6 

IV. The Presumptive Norm for Graphic J\rts 

In the CTG document entitled "Control of Volatile Organic Emissions 

from Existing Stationary Sources--Volume VIII: Graphic Arts--

Rotogravure and Flexographyll (the llCTGll), EPA presented emission 

limits based on the capabilities and problems general to the 

industry. These limits known as the "presumptive norm" form the 

basis for the SIP requirements for rotogravure packaging plants. 

The SIP essentially requires a 65 percent control level for sources 

with greater than 100 tons per year of emissions_ As shown in 

Figure 4.4 and 4.5 (attached), which are extracted from the CTG, at 

approximately the 100 tpy emission level, EPA expected the costeffectiveness 6f the "presumptive norm" (using incineration 

devices) to be approximately $2,000 per ton of VOC removed (in 1978 

dollars). 

V. capital and Operating Costs of incineration 

The formal "En gineers Estimate" for installing an 

incinerator on the Laminator is attached. As shown in the 

estimate, Reynolds estimates that the capital cost of the 

incinerator would be $1,890,000. Based on Bellwood Printing 

Plant's experience with other.incinerators, the Company believes 

that operating costs for the incinerator would be approximately 

$225,000 per year. 
7 

VI. Cost Effectiveness of VOC Control on the Laminator 

The positive pressure system ovens of the Laminator makes fume 

capture very difficult and separates this piece of equipment from 

EPA's "presumptive norm". 

Based on theunique oven configuration of the Laminator, 

Reynolds estimates that fume capture efficiency for the Laminator 

would be approximately 50 percent. The Laminator has annual 

projected emissions of 203 tons per year and an incinerator would 

be expected to destroy 90 percent of the VOC delivered to the 

unit. (A) Thus, if an incinerator were added, and the Laminator 

was operating at full capacity, it would potentially abate 91.35 

tons per year of VOC. 

The total capital cost of the incinerator may be annualized 

by using a Capital Recovery Factor (CRF) . 

CRF i + ilt(,+i)n ,) 

(A)This analysis is focused on the addition of incineration 

equipment. The same conclusions would apply if the cost of carbon 

adsorption equipment was utilized. Also, although Reynolds 

continues to study low solvent technology, it should be 

recognized that low solvent technology is not presently 

commercially available for the products produced on this piece of 

equipment. 
Assuming a 10 year life for the incinerator and i=J2 percent, the 

CRF equals 17.70% and the annualized capital charge would equal 

(.1770) ($1,890,000) or $334,530. 

Thus, the annualized incinerator cost would be $334,530 for 

capital cost plus $225,000 for operating costs for a total cost 

of about $559,000. 

The incinerator would potentially abate 91.35 tons per year of 

VOC. Thus, the cost-effectiveness of VOC control by 

incineration for the Laminator is $559,000/91.35 or $6125/ton. 

VII. Compa:r.ison to the P-resum-pti@e Norm for Graiphic Arts 

clearly, the cost of adding incineration equipment on the 

Laminator grossly exceeds the cost of EPA's "presumptive norm" or 

cost-effectiveness gauge and, in our opinion, it would not be 

reasonable, nor would it constitute RACT. The cost-effectiveness 

of incineration for the Laminator is $6,125 per ton of VOC 

abated. The EPA presumptive norm cost-effectiveness measure, even 

adjusted for inflation, is still only $3,137, based on the cost 

index in the 9th annual edition of Means Mechanical Cost Data 

Accordingly, as stated above, incineration of emissions from the 

Laminator would be nearly twice the EPA presumptive norm cost 

and, quite clearly, would be unreasonable and well beyond 

recommended RACT. 
9 

VIII. Comparison to Mr. G. A. Emison of EPA's Guidance of 

April 11, 19 8 6 

The type of analysis presented in this document is exactly the 

type of case-by-case review to detlermine RACT which is advocated 

in Mr. Emison's guidance. Additionally, the technological 

problems in fume capture, which separates this source from the 

type of CTG source studied by EPA, are taken into account in this 

analyses. 

The economic feasibility criterion of RACT, in regards to 

the cost-effectiveness of control on the Laminator, is well 

discussed in this document. 

Other factors referenced in Mr. Emison's guidance include: 

1. Age of Facility- The Laminator is an aged piece of 

equipment which is some 18 years old. 

2. Severity of Air Quality Problem - The Richmond area has 

experienced two consecutive years of meeting the ozone 

ambient air quality standard. If this year follows the 

trend of the past, the Richmond area can be 

reclassified to attainment status next year. In any 

event, the ozone air quality situation in the Richmond 

area is not "severe". 
10 

3. comparability to standard Industry Practice As 

illustrated in this document, the Laminator is a unique 

piece of equipment which does not fit the "presumptive 

norm". 

4. Cross Media Impacts -There would be no adverse cross 

media impacts. 

In summary, Reynolds has performed the type of analysis 

envisioned by the Emison guidance. The analysis supports the 

conclusion that an annual emission limit of 203 tons per year 

constitutes RACT for the Laminator. 

IX. Comparison lo Other EPA RACT Determinations 

In developing RACT recommendations for other source 

categories, EPA has established cost-effectiveness values for a 

number of web source categories as shown below: 

RACT Cost 

$/Ton VOC Removed 

SOURCE (1977 dollars) 

Coil Coating 

(operating Costs Only) 44 153 

Fabric Coating 

Carbon Adsorption 157 - 721 

incineration 13 - 54 

Paper Coating 

carbon Adsorption 50 - 125 

incineration 13 - 51 
The above figures represent the presumptive norm costs for RACT 

on other source categories. These figures are all well within 

$1,120 per ton of VOC removed when adjusted to 1986 dollars. 

Thus, the cost of incineration on the Laminator would be about 

five times as expensive as the costs EPA has expected other 

source owners to spe;d. In our view, the incineration of 

emissions from the Laminator would clearly exceed the RACT cost 

levels experienced in other industries. 

X. Comparison to EPA Region III Guidance Report 

In 1984, U.S. Environmental Protection Agency Region III 

representatives gave the State Air Pollution control Board and 

Reynolds a copy of a document entitled "Determination of ' Plant-

-Specific RACT for the Paper and Fabric Coating Industries in 

Massachusetts." EPA noted that this document would be a good 

guide for Reynolds to use. in this document it is stated that, 

"The consensus reached among the TRC engineering team was that 

costs in excess of $2500/ton VOC controlled would constitute an 

unacceptably poor cost-effectiveness." It is our understanding 

that this report provided the basis for RACT determinations in 

EPA Region II for the referenced sources. Adjusted to 1986 

dollars, the cost-effectiveness criterion used in this 

recommended EPA Region III guide would be $3,236/ton VOC 

controlled. 
12 

As previously stated, it would cost $6,125 per ton of VOC 

removed to add incineration at the Laminator. When compared to 

the EPA Region III recommended guide of $3,236 per ton VOC 

controlled, it is once again clear that incineration of 

emissions from the Laminator would not be cost-effective and 

would not represent RACT as determined for other VOC sour ces. 

XI. Other Source Specific RACT Determinations in Virginia 

In 1985, the SAPCB approved a source specific RACT for 

another Richnond area source. The projected cost-effectiveness 

value for adding incineration equipment on the Laminator exceeds 

the value approved for this other source. 

XII. Conclusion on Source-Specific RACT Determination for the 

Laminator 

Due to the unique nature of the Laminator and since no low 

solvent technology currently exists for the Laminator, Reynolds 

Metals Company believes that RACT for the Laminator should be 

defined as an annual emission limit of 203 tons per year. We 

believe that we have documented that incineration would be 

unreasonably expensive and exceed RACT. Reynolds is, however, 

continuing research and development of low solvent technology for 

the Laminator and is willing to provide the SAPCB with periodic 

reports on the status of low solvent technology for the 

Laminator. 
1 2 

1 0 

a EMISSIONS AT 500 PPM VOC 

a o EMISSIONS AT 1500 PPM 'ODE 

4 

2 

30 00 2500 

(3301 40) (550) (16501 (2750) 

ANNUAL PLANT INK USAGE. M91yr (ton/yr) 

Figure 4-4. Cost-effectiveness of thermal incineration without heat 

recovery for VOC control of rotogravure printing process at graphic 

arts plant. 

g I ti 

4-22 
f 

12 

lo 

& EMISSIONS AT 500 ppm V(C 0 

EMISSIONS AT ISOO ppm VOC 

6 

0 

4 

(110) (220) (3J0) (440) (1, 6--5-G) (2750) 

ANNUAL PLANT INK USAGE, Mglyr (ton/yr) 

Figure 4-5. Cost-effectiveness of thermal incineration control with 

40 percent heat recovery for VOC of rotogravure printing Process at 

graphic arts plant. 

4-23 
VIS FORM 13 PRINTED ON XII D11PirOArGR AND CAY BE USED AS A MASTER FOR 25 COPT 

E.7 OR LESS. 

ENGINEERS ESTIMATE 

1EQUIPMEPT, MATERIAL. AND LABOR F02 INSTALLATION REQUIRED) 

SUBJECT INCINERATOR FOR NO. 3,LAMINATOR PAGE 00. 

DATE June 16, 1 986 

ESTIMATE NO. 

PLANT Bellwood Printing DEPARTMENT 7515 

No. DESCRIPTION OUANTITY UNIT COST ]TEN; COST 

CUNT 

1.0 Site Preparation and Improvements 

2.0 Buildings 

3.0 Modifications to Existing Buildings 25,0i 

4.0 Special Enclosures 

5.0 Structural Steel (Other Than Building) 50,0C 

6.0 Foundations 10,0C 

7.0 Mechanical Equipment Acquisition 1,090,00 

8.0 Mechanical Installation 

8.1 Labor 60 000 

8.2 Material 60:000 120,00 

9.0 Piping (Process & Machinery) 

9.1 Piping' I.-i,uuu 

9.2 Insulation 25,000 40.00 

0.0 Electrical Equipment Acquisition 50,00 

1.0 Electrical Installation 50.00 
211S JOR9 IS PRINYRD OX 204 DUPLICATOR AND CAI BE USED AS A ArASTER rOR 26 COP 

IES OR LESS. 

ENGINEERS ESTIMATE 

(EQUIPMENT, MATERIAL. AND LABOR FOR INSTALLATION REQUIRED) 

ZUBJECT INCINERATOR FOR NO. 3 LAMINATOR PAGE NC. 7 

DATE June I 1986 

ESTIMATE NO. 

PLANT Bellwood Printin, DEPARTMENT 7515 

XCOUNT 

DESCRIPTION QUANTITY UNIT COST ITEM COST 

140. 

12.0 Pollution Control Equipment (Air, Water, Noise) 

11.0 Modification to EXiSting Equipment 130,0 

114.0 Material liandling Equipment 

15.0 Fuel Storage and Distribution Systems 

@6.0 Fire Protection Equipment 

7.0 OfficePurniture and Equipment 

18.0 Unclassified 
F) .0 Freight 10,0( 

1.0 Engineering @ 10 

158,0C 

1.0 Contingency @ 10% 158,0C 

l$1,89l.oc 

Project to be completed 15 months after approval. 

Project will be Closed 18 months after aDDrOVal of proje t. 

W. A. Via, Printing Unit Engineering Manager 
ENCLOSURE 2

PUBLIC PARTICIPATION CERTIFICATION

AND COMPLIANCE WITH

STATE ADMINISTRATIVE PROCEDURES

As required by 40 CFR 51.102(a), a public comment period to provide the opportunity to 

submit written comments concerning a proposed revision to the Commonwealth of 

Virginia State Implementation Plan was held from September 16 to October 19, 2015.

As required by 40 CFR Part 51.102(a) and (d)(1) and (2), the public was given notice of 

the public comment period in Style Weekly, along with the location of the proposal for 

public inspection, on September 16, 2015. The notice included procedures to afford 

the public the opportunity to request that a hearing be held pursuant to 40 CFR 

51.102(a); no such request was received. The attached copy of the notice provides the 

evidence required by Section 2.1(f) of Appendix V of 40 CFR Part 51.

The Regional Administrator for the U.S. Environmental Protection Agency was notified of 

the hearing in accordance with the requirements of 40 CFR Part 51.102(d).

Any comment received and responses thereto are found in Enclosure 3.

As required by Section 2.1(b) of Appendix V of 40 CFR Part 51, the permit was issued

by the Department of Environmental Quality on October 20, 2015, to be effective that 

same day. The statement of authority and procedures followed for approval and 

issuance of the permit and the signature of the Regional Director on the permit are 

included in Attachment A to Enclosure 1, providing the evidence required by Section 

2.1(b) and (e) of Appendix V of 40 CFR Part 51. As required by Section 2.1(d) of 

Appendix V of 40 CFR Part 51, a copy of the actual permit submitted for approval and 

incorporation by reference into the Commonwealth of Virginia SIP is included in 

Attachment A to Enclosure 1.

TEMPLATES\SOURCE-SPECIFIC\PLN02

RACT\RICHMOND6\RCP-SIP-2.DOC
STYLE WEEKLY 

RICHMOND, VIRGINIA 

AFFIDAVIT OF PUBLICATION 

STYLE WEEKLY 

- - - - - - - - - - - - - - - --- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - +- - - - - - - - - - - - - - - - - ED -PR 0 

DEQ-PRO : RECElV ~~:~ ~L~~~ ~~AD 2 3 0 6 0 : s~~ 2Z ~ 1mS) 

REFERENCE: SW002714 

SW25686 

State of Virginia 

City of Richmond 

Public Notice,Reynol 

This day, Kimberly Hall appeared before me and, 

after being duly sworn, made oath that: l) She is 

affidavit clerk of Style Weekly, a 

newspaper published by Pilot Media Companies, LLC, 

in the city of Richmond and the counties of 

Chesterfield, Henrico and Hanover in the 

commonwealth of Virginia, and 2_) That the 

advertisement hereto annexed has been published in 

said newspaper on the dates stated 

PUBLISHED ON: 09/16 

I 

I 

I 

I 

I 

I 

I 

SlYlfE ·WfEEKl y PA~D 

I 

I 

LINE I 

Notary: 

I 

and state on the day·and year 

year of 2015. (NRN: 7209857) 

""--=o-'-!~~.11£1V-li...K-L-l£-\-\,/.'!C..U.:~!__~=/'Y commission expires l, )- "bO- ·[ ,b 
Public NoticeEnvironmental Permit 

PURPOSE OF NOTICE: The Department of Environmental Quality (DEQ) 

is announcmg a public comment period 

on a state operating permit to limit air 

pollution emitted by a facility in Chesterfield County, Virginia If adopted, 

the Commonwealth intends to submit 

the penmt as a revision to the Commonwealth of V~rgmta State Implementation Plan (SIP) in accordance 

wtth the reqmrements of§ IIO(a) of the 

federal Clean Air Act The SIP ts the 

plan developed by th~ Commonwealth 

m order to fulfill its responstbilities under the federal Clean Air Act to attain 

and maintain the ambient air quahty 

standards promulgated by the U.S. Environmental Protection Agency (EPA) 

under the Act. 

PUBLIC COMMENT PERfOD. Sep· 

tember 16,2015 to October 19,2015 

PERMIT NAME: State Operating Perrott tssued by DEQ, under the authority 

of the Air PollutiOn Control Board 

APPLICANT NAME, ADDRESS, 

AND REGISTRATION NUMBER: 

Reynolds Consumer Products LLC -

Bellwood Printing Plant; 200 I Reymet 

Road, Richmond (Chesterfield County), VA 23237;50260 

DESCRIPTION OF PROPOSAL: The 

proposed revtsion consists of converting a consent order for reasonably 

available control technology (RACT) 

mto a state operating permit and makmg several techmcal corrections. This 

permit is for the control of emissions 

of volattle organic compounds (VOC) 

to the atmosphere from Reynolds 

Consumer Products LLC - Bellwood 

Printmg Plant located in Chesterfield 

County, Virgtma. The changes have 

been requested to correct typographical 

errors in the formula used to calculate 

the daily reduction m VOC emtssions. 

The current definitions for X 14 and 

XIS are X14 =Xl4+X5+X6+X7+X8 

+X9+XIO+Xli+Xl2+Xl3, and XIS 

= XI4+XO+XI+X2+X3- Xl4- X5-

X6 - X7. These must be corrected to 

Xl4 = X4 +X5 +X6 +X7 +X8 +X9 

+XIO+XII+XI2+XI3, and XIS = 

XI4+XO+XI+X2+X3 • X4 · X5 • X6-

X7 Thts change is admmtstrative and 

wtll have no effect on facility operation 

or air quality. 

FEDRAL INFORMATION This notice is being given to satisfY the pubhc 

participation requirements of federal 

regulatwns ( 40 CFR 51 I 02) The 

proposal wtll be submttted as a revtsion to the Commonwealth of Virgmia 

SIP under §IIO(a) of the federal Clean 

Air Act m accordance with 40 CFR 

51.104. It is planned to submtt all pro-

. visions of the proposal as a reviston to 

the SIP 

HOW TO COMMENT AND/OR REQUEST A PUBLIC HEARJNG: DEQ 

accepts comments and requests for 

pubhc heanng by hand-delivery, email~ fax or postal mail. All comments 

and requests must be in writing and 

be received by DEQ during the comment period. Submtttals must include 

the names, mailing addresses and tele· 

phone numbers of the commenter/requester and of all persons represented 

by the commenter/requester. Please 

note thts draft permit is being concurrently revtewed as a proposed penni! 

by the U.S. Envtronmental Protection 

Agency 

Contact for public comments, document requests and additional infonnatton. Cheryl Mayo; Piedmont Regional 

Office, 4949-A Cox Rd., Glen Al\en, 

VA 23060; Phone (804)527-5031; Email: Cheryi.Mayo@deq virginia.gov; 

Fax· (804) 527-5106 The pubhc may 

revtew the draft permit and application at the QEQ office named above by 

appointment or may request copies of 

the docunients from the contact person 

listed above. The draft permit is also 

avatlable on the DEQ website at www. 

deq virgtma.gov/programs/air/publicnottces/airpenntts.aspx. 
STYLE WEEKLY 

RICHMOND, VIRGINIA 

AFFIDAVIT OF PUBLICATION 

STYLE WEEKLY 

- - - - - - - - - - - - - - - --- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - +- - - - - - - - - - - - - - - - - ED -PR 0 

DEQ-PRO : RECElV ~~:~ ~L~~~ ~~AD 2 3 0 6 0 : s~~ 2Z ~ 1mS) 

REFERENCE: SW002714 

SW25686 

State of Virginia 

City of Richmond 

Public Notice,Reynol 

This day, Kimberly Hall appeared before me and, 

after being duly sworn, made oath that: l) She is 

affidavit clerk of Style Weekly, a 

newspaper published by Pilot Media Companies, LLC, 

in the city of Richmond and the counties of 

Chesterfield, Henrico and Hanover in the 

commonwealth of Virginia, and 2_) That the 

advertisement hereto annexed has been published in 

said newspaper on the dates stated 

PUBLISHED ON: 09/16 

I 

I 

I 

I 

I 

I 

I 

SlYlfE ·WfEEKl y PA~D 

I 

I 

LINE I 

Notary: 

I 

and state on the day·and year 

year of 2015. (NRN: 7209857) 

""--=o-'-!~~.11£1V-li...K-L-l£-\-\,/.'!C..U.:~!__~=/'Y commission expires l, )- "bO- ·[ ,b 
Public NoticeEnvironmental Permit 

PURPOSE OF NOTICE: The Department of Environmental Quality (DEQ) 

is announcmg a public comment period 

on a state operating permit to limit air 

pollution emitted by a facility in Chesterfield County, Virginia If adopted, 

the Commonwealth intends to submit 

the penmt as a revision to the Commonwealth of V~rgmta State Implementation Plan (SIP) in accordance 

wtth the reqmrements of§ IIO(a) of the 

federal Clean Air Act The SIP ts the 

plan developed by th~ Commonwealth 

m order to fulfill its responstbilities under the federal Clean Air Act to attain 

and maintain the ambient air quahty 

standards promulgated by the U.S. Environmental Protection Agency (EPA) 

under the Act. 

PUBLIC COMMENT PERfOD. Sep· 

tember 16,2015 to October 19,2015 

PERMIT NAME: State Operating Perrott tssued by DEQ, under the authority 

of the Air PollutiOn Control Board 

APPLICANT NAME, ADDRESS, 

AND REGISTRATION NUMBER: 

Reynolds Consumer Products LLC -

Bellwood Printing Plant; 200 I Reymet 

Road, Richmond (Chesterfield County), VA 23237;50260 

DESCRIPTION OF PROPOSAL: The 

proposed revtsion consists of converting a consent order for reasonably 

available control technology (RACT) 

mto a state operating permit and makmg several techmcal corrections. This 

permit is for the control of emissions 

of volattle organic compounds (VOC) 

to the atmosphere from Reynolds 

Consumer Products LLC - Bellwood 

Printmg Plant located in Chesterfield 

County, Virgtma. The changes have 

been requested to correct typographical 

errors in the formula used to calculate 

the daily reduction m VOC emtssions. 

The current definitions for X 14 and 

XIS are X14 =Xl4+X5+X6+X7+X8 

+X9+XIO+Xli+Xl2+Xl3, and XIS 

= XI4+XO+XI+X2+X3- Xl4- X5-

X6 - X7. These must be corrected to 

Xl4 = X4 +X5 +X6 +X7 +X8 +X9 

+XIO+XII+XI2+XI3, and XIS = 

XI4+XO+XI+X2+X3 • X4 · X5 • X6-

X7 Thts change is admmtstrative and 

wtll have no effect on facility operation 

or air quality. 

FEDRAL INFORMATION This notice is being given to satisfY the pubhc 

participation requirements of federal 

regulatwns ( 40 CFR 51 I 02) The 

proposal wtll be submttted as a revtsion to the Commonwealth of Virgmia 

SIP under §IIO(a) of the federal Clean 

Air Act m accordance with 40 CFR 

51.104. It is planned to submtt all pro-

. visions of the proposal as a reviston to 

the SIP 

HOW TO COMMENT AND/OR REQUEST A PUBLIC HEARJNG: DEQ 

accepts comments and requests for 

pubhc heanng by hand-delivery, email~ fax or postal mail. All comments 

and requests must be in writing and 

be received by DEQ during the comment period. Submtttals must include 

the names, mailing addresses and tele· 

phone numbers of the commenter/requester and of all persons represented 

by the commenter/requester. Please 

note thts draft permit is being concurrently revtewed as a proposed penni! 

by the U.S. Envtronmental Protection 

Agency 

Contact for public comments, document requests and additional infonnatton. Cheryl Mayo; Piedmont Regional 

Office, 4949-A Cox Rd., Glen Al\en, 

VA 23060; Phone (804)527-5031; Email: Cheryi.Mayo@deq virginia.gov; 

Fax· (804) 527-5106 The pubhc may 

revtew the draft permit and application at the QEQ office named above by 

appointment or may request copies of 

the docunients from the contact person 

listed above. The draft permit is also 

avatlable on the DEQ website at www. 

deq virgtma.gov/programs/air/publicnottces/airpenntts.aspx. 
1

ENCLOSURE 3

RECORD OF HEARING AND SUMMARY OF PUBLIC COMMENT

As required by 40 CFR 51.102(e), the complete record of the hearing, along with a list 

of attendees and the text of the written presentations or summary of the oral 

presentations, is located at the Air Division of the Department of Environmental Quality. 

The department contact to access this information is the Director, Air Division.

The state did not receive comment on this particular revision. 

TEMPLATES\RACT\PLN03

RACT\RICHMOND6\RCP-SIP-3.DOC