Molly Joseph Ward Secretary ofNatural Resources 

# COMMONWEALTHofVIRGINIA DEPARTMENTOFENVIRONMENTAL 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 62015

Ms. DianaEsher, Director AirProtectionDivision 

## (3APOO) U.S. Environmental ProtectionAgency, RegionIII 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 David K. Paylor Director (804) 698-4020 1-800-592-5482



### Reference: SIP Revisionfor Reynolds ConsumerProducts DearMs. Esher: Pursuantto therequirements of§ 110 ofthe CleanAirAct, we are officiallyrequesting approval ofa revisionto the CommonwealthofVirginia State ImplementationPlan (SIP) approved onFebruary 11,2014underthe authority of§ 10.1-1185 ofthe Code ofVirginiaand submittedin accordance withthe requirements of40 CFRPart51 (Requirements for Preparation, Adoption, and Submittal oflmplementationPlans). Theplanrevisionis effective uponthe date ofapproval, October 20,2015. Therevisionconsists ofa federally enforceable state operatingpermitcontainingterms and conditions for the control ofemissions ofvolatile organic compounds (VOCs) from the Reynolds ConsumerProducts LLC- BellwoodPrinting Plant (RegistrationNo. 50260) located in Chesterfield, Virginia. Thepurpose ofthis revisionis to convert a consentorderfor reasonably available control technology (RACT) into a state operatingpermit. A number of technical corrections are being made as well

. Withthis letterwerequestremoval ofthe original consentorderfrom the SIP.

### Enclosed are the following: 1. SIP revision, includingthe federally enforceable state operatingpermit. 2. Publicparticipationcertification and compliance with state administrativeprocedures. 3. Summary ofpublic comment andresponses thereto.

Ifyouhave any questions orneed additional information, please letus 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)

.MollyJoseph Ward Secretary ofNatura! Resources 

# COMMONWEALTHofVIRGINIA DEPARTMENTOFENVIRONMENTAL 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 PERMITTO OPERATE David K. Paylor Director Michael P. Murphy Regional Director



### This permitimplements the requirements forReasonablyAvailable Control Technology (RACT) for Volatile Organic Compounds (VOC) in the Richmond,VirginiaEmissions ControlArea. This pennit (i) 

### is for the purpose ofimplementing the "reasonably available control technology" (RACT) requirements of9VAC 5-40-7390 oftheRegulations ofthe Board and (ii) establishes control technology and otherrequirements for the control ofvolatile organic compound (VOC) emissions from the Reynolds Consumer Products LLC- Bellwood Printing Plant in the Richmond, Virginia OzoneMaintenance 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 of40 CFRPart 51 (Requirements for Preparation, Adoption, and Submittal ofImplementation Plans) and upon such approval this permit shall supersedeyourconsent orderdated October 31, 1986. In compliance with theFederal Clean AirAct and the Commonwealth ofVirginiaRegulations for the Control and Abatement ofAirPollution,

is authorizedto operate

located at Reynolds ConsumerProducts LLC Bellwood PrintingPlant 2001 Reymet Road Richmond, VA 23237 Registration No.: 50260

a printingfacility

2001 ReymetRoad Chesterfield County, Virginia in accordance with the Conditions ofthis pennit. Approved on October20, 2015.

Permit consists of5pages. Pe1mit Conditions 1to 15. AirPermit Manager

## Reynolds ConsumerProducts LLC Bellwood Printing Plant 50260 October20, 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 ofthe facility on air quality mayrequire apermit. Failure to obtain such apermitpriorto construction may result in enforcement action. Words orterms used in this permit shall have meanings as provided in 9 VAC 5-10-20 ofthe State Air Pollution Control Board Regulations for the Control and Abatement ofAir 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 promptresponse bythe permittee to requests by the DEQ orthe Boardfor informationto include, as appropriate: process andproduction data; changes in control equipment; and operating schedules. Such requests for information from the DEQ will eitherbe in writing orbypersonal contact. The availability ofinformation submitted to the DEQ orthe Board will be governed by applicable provisions oftheFreedom oflnformationAct,§§ 2.2-3700 through 2.2-3714 ofthe Code ofVirginia, § 10.1-1314 (addressing information provided to the Board) ofthe Code ofVirginia, and 9 VAC 5-170- 60 ofthe State AirPollution Control Board Regulations. Informationprovided to federal officials is subjectto appropriate federal law and regulations governing confidentiality ofsuch information. GroupA Facilities The GroupA Facilities at the Plant*are: PressesNumber 1, 2, 4, ExtrudersNumber 1, 2. and3, 

## andthe treatingstation forPressNumber 3. 

## ** UnitID EquipmentDescription Rated Capacity 21-1 ChamplainPress 1with 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-1975) 800ft/min 21-3 Champlain Press 3 (treating station only) N/A 21-4 Champlain Press 4 for film, foil andpaper (pre-1975) 710ft/min 21-10 Egan Extruder 1for film, foil and paper (pre-1975) 1,010 ft/min 21-11 Dilts/EganTandem Extruder 2 for film, foil and paper (pre-1975) 1,025 ft/min 21-12 Dilts/EganTandem Extruder 3 for film, foil and paper (pre-1975) 1,000 ft/min AdditionalEquipment 24 IntraRoto Laminator 3for film, foil and paper (pre-1975) 1,000 ft/min Specifications included in the above tables are for informational purposes only and do not form enforceable terms orconditions ofthe permit. * "Plant"refersto Reynolds ConsumerProducts LLC (- BellwoodPrinting 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 Extruder4.

## PROCESSREQUIREMENTS

- VOC Emission Controls Reynolds Consumer ProductsLLC Bellwood Printing Plant 50260 October20,2015 Page 3

1. Emission Controls-VolatileOrganic Compound emissions from the affected facilities atthe Plant shall be controlled and reduced as outlined in this permit. (9 VAC 5-40-7370 and 9 VAC 5-80-850) 2. Emission Controls The ''Group A facilities" atthe 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 VAC 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 dailybasis overthe historical amount ofsolvent used to apply the same amount ofsolids. 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 ofConditions 2 and 3 for the Group A facilities will be determined by the use ofa "DailyVOC Model". The model will calculate daily emission reductions by comparing actual material usings to the historical amount ofsolventbearingmaterial used. The model will calculate daily emissionsbymeasuring, on ajobbasis, all VOC bearing materials consumed. TotaljobVOC usings shall be apportioned to individual days based on productionrecords. The daily historical amount ofsolventwhich would have been used shall be calculatedby factors relating the daily amount ofapplied solids and the historical amount ofsolvent required to apply apound ofsolids. The historical factors and compliance calculations are shown in Attachment A. 

## (9 VAC 5-40-7370 and 9VAC 5-80-850) EMISSIONS LIMITATIONS 5. Process EmissionLimits- The Boardhas determinedthat RACT for No.3 Laminatoris an emission limitof2.0tons per day. AttachmentB to this permit outlines the basis for this determination. (9 VAC 5-40-7370 and 9VAC 5-80-850) RECORDS 6. On Site Records

- The permittee shall maintainrecords ofemission data and operatingparameters as necessary to demonstrate compliance with this permit. The content and format ofsuch records shall be arranged withthe Piedmont Regional Office. These records shall include, but are not limited to: Records consisting ofinformation as to the calculated dailyreduction in emissions ofVolatile Organic Compounds from the Group A facilities, exceptthose emissions treated by add-on control equipment at the Plant.

### Reynolds Consumer Products LLC Bellwood PrintingPlant 50260 October 20, 2015 Page4 These records shall be available for inspectionbythe DEQ and shall be current for the mostrecent two years. (9 VAC 5-40-7370 and 9 VAC 5-80-850) 

## NOTIFICATIONS 7. 

## Exception Reports- Reynolds ConsumerProducts LLC shall provide the Board an exception report atthe end ofany quarter when conditions 1, 2, or 3 ofthis permit are not met. (9 VAC 5-80-850) 

## TESTING 8. 

## Emission Testing- The printingfacility shall be constructed so as to allow for emissions testing upon reasonable notice at any time, using appropriate methods. Samplingports shall be provided when requested at the appropriate locations, and safe samplingplatforms and access shall be provided. (9 VAC 5-80-880 and 9 VAC 5-80-850) 

## GENERAL CONDITIONS 9. 

## Relationship to OtherPermitRequirements- Exceptto the extent that conditions in thispermit may be more stringent, this permitdoes not supersede orreplace any othervalid permit, orany other regulatory or statutory requirement. Furthermore, this approval to operate shall notrelieve Reynolds ConsumerProducts LLC ofthe responsibilityto complywith all other local, state and federal regulations, includingpermitregulations. (9 VAC 5-80-800 D and 9 VAC 5-80-820 F) 10. 

## FederalEnforceability- Once this permitis approved bythe U.S. Environmental Protection Agency into the Commonwealth ofVirginia State Implementation Plan, thepermitis enforceable by EPA and citizens underthe federal CleanAirAct. (9 VAC 5-80-800 C.2 and 9 VAC -5-80-820 F) 11. 

## PermitModification- The Boardmayrevise (modifY, rev..rrite, change oramend) orrepeal this permit withthe consent ofReynolds ConsumerProducts LLC, for good cause shownby Reynolds ConsumerProducts LLC, oron its ownmotionprovided approval ofthe revision orrepeal is accomplished in accordance with the Regulations ofthe Board and the Administrative Process Act (§2.2-4000 et seq.). Suchrevision orrepeal shall not be effective until the revision orrepeal is approved bythe U.S. Environmental ProtectionAgency following the requirements of40 CFRPart 51 (Requirements for Preparation, Adoption, and Submittal ofimplementationPlans). (9 VAC 5-80-960 and 5-80-1000) 12. 

## Failureto Comply- FailurebyReynolds ConsumerProductsLLC to comply with any ofthe conditions ofthis permit shall constitute a violation ofa Permit ofthe Board. Failureto complymay result in a Notice ofViolation and civil penalty. Nothing herein shall waive the initiation of appropriate enforcement actions orthe issuance oforders as appropriate by the Board as a result of

### Reynolds ConsumerProducts LLC Bellwood PrintingPlant 50260 October20, 2015 Page 5 such violations. Nothingherein shall affect appropriate enforcement actions by any other federal, state, orlocal regulatory authority. (9 VAC 5-80-820 F, 9 VAC 5-80-910, and 9 VAC 5-80-1010) 13. 

### Right ofEntry

- The permittee shall allow authorized local, state, and federal representatives, upon thepresentation ofcredentials:

a. To enteruponthe permittee'spremises on which the facility is located orin which any records are requiredto be kept underthe terms and conditions ofthis permit; b. To have access to and copy atreasonable times any records required to be kept under the terms and conditions ofthis permit orthe State AirPollution Control Board Regulations;

c. To inspect at reasonable times any facility, equipment, orprocess subject to the terms and conditions ofthis permitorthe State AirPollution Control BoardRegulations; and d. To sample ortest at reasonable times. Forpurposes ofthis condition, the time for inspection shall be deemed reasonable during regular businesshours orwheneverthe facility is in operation. Nothing contained herein shall make an inspection time unreasonable during an emergency. (9 VAC 5-170-130 and 9 VAC 5-80-850) 14. 

### Change ofOwnership

- Inthe case ofa transferofownership ofa stationary source, the newowner shall abide by any currentpermitissued to the previous owner. Thenewowner shall notifythe Piedmont Regional Office ofthe change ofownership within 30 days ofthe transfer. (9 VAC 5-80-940) 15. 

### PermitCopy

- Thepermittee shall keep a copy ofthispermit onthe premises ofthe facility to which it applies. (9 VAC 5-80-860D)

# 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 Constantbased on two year solvent/solid ratio for solvent 0/C* Constant based on two year solvent/solidratio for solvent treating Constant based on two year solvent/solid ratio for solventthermos and H/S* Calculated solvents replaced byWB* 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 ofraw solvent used Total actual solvent usage for time period Total estimated solvents the plant is capable ofusing 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 ATTACTHM ENTB



### 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



## LaminatorNo. 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 ofair 

## 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 artsplants.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 70) ($1 , 8 90, 000 ) or $ 

### 3 3 4 , 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. 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 (1977 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 ofthermal 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

# ~J u 

## !**;tt~** !

### 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 1 14-1129-41 VIES PORNIS RRIXTED 01 Xi(DUPLICANRA10 CAP. BE USEDASAMASTER FOR23 COPIES ORLESS.

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 theaffected 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 vvith 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. WeissREYNOLDS 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 substratecauses 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 standardindustry 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, 198 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

- 51The 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 4-22f

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.

4-23VIS 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 50.00211S 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 UnclassifiedF) .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
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-2.DOCSTYLE WEEKLY RICHMOND, VIRGINIA AFFIDAVIT OF PUBLICATION STYLE WEEKLY

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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 

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Notary: 

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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- ·[,bPublic NoticeEnvironmental Permit PURPOSE OF NOTICE: The Department ofEnvironmental Quality (DEQ) is announcmg apublic commentperiod 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) ofthe federal Clean Air Act The SIP ts the plan developed by**th~** Commonwealth morderto 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 tssuedby DEQ, underthe authority oftheAir PollutiOn Control Board APPLICANT NAME, ADDRESS, AND REGISTRATION NUMBER: Reynolds Consumer Products LLC

- Bellwood Printing Plant; 200I Reymet Road, Richmond (Chesterfield County), VA 23237;50260 DESCRIPTION OF PROPOSAL: The proposed revtsion consists ofconverting 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 ofemissions ofvolattle organic compounds (VOC) to the atmosphere from Reynolds Consumer Products LLC

- Bellwood Printmg Plant located in Chesterfield County, Virgtma. The changes have been requested tocorrecttypographical errors in the formula used to calculate the daily reduction m VOC emtssions. The current definitions for X14 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 noeffecton facility operation or air quality. FEDRAL INFORMATION This notice is beinggiven to satisfY the pubhc participation requirements of federal regulatwns (40 CFR 51 I02) The proposal wtll be submttted as a revtsion to the Commonwealth ofVirgmia SIP under §IIO(a) ofthe federal Clean Air Act m accordance with 40 CFR 51.104. It is planned to submtt all pro-

. visions ofthe 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, e**mail~** 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 ofall 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

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# ED

# -PR0 DEQ-PRO : 

# RECElV**~~:~ ~L~~~** **~~AD**2 3060 :

## 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 

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# SlYlfE·WfEEKly**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- ·[,bPublic NoticeEnvironmental Permit PURPOSE OF NOTICE: The Department ofEnvironmental Quality (DEQ) is announcmg apublic commentperiod 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) ofthe federal Clean Air Act The SIP ts the plan developed by**th~** Commonwealth morderto 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 tssuedby DEQ, underthe authority oftheAir PollutiOn Control Board APPLICANT NAME, ADDRESS, AND REGISTRATION NUMBER: Reynolds Consumer Products LLC

- Bellwood Printing Plant; 200I Reymet Road, Richmond (Chesterfield County), VA 23237;50260 DESCRIPTION OF PROPOSAL: The proposed revtsion consists ofconverting 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 ofemissions ofvolattle organic compounds (VOC) to the atmosphere from Reynolds Consumer Products LLC

- Bellwood Printmg Plant located in Chesterfield County, Virgtma. The changes have been requested tocorrecttypographical errors in the formula used to calculate the daily reduction m VOC emtssions. The current definitions for X14 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 noeffecton facility operation or air quality. FEDRAL INFORMATION This notice is beinggiven to satisfY the pubhc participation requirements of federal regulatwns (40 CFR 51 I02) The proposal wtll be submttted as a revtsion to the Commonwealth ofVirgmia SIP under §IIO(a) ofthe federal Clean Air Act m accordance with 40 CFR 51.104. It is planned to submtt all pro-

. visions ofthe 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, e**mail~** 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 ofall 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