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 TDD (804) 698-4021 

www .deq. virginia.gov 

FEB 14 2014 

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 Mondelez 

Global LLC, Inc. (formerly 

Kraft Foods) 

Dear Ms. Esher: 

Pursuant to the requirements of § 11 0 of the Clean Air Act, we are officiaJly 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 of Implementation Plans). The plan revision is effective upon the date 

of approval, February 11 , 2014. 

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 

Mondelez Global LLC, Inc. (formerly Kraft Foods Global, Inc.) located in Henrico County, 

Virginia. This submittal is for the pirrpose of meeting the requirements for Reasonably Available 

Control Technology (RACT) in order to implement the attainment and maintenance plans for the 

Richmond Ozone Maintenance Area. This revision is intended to replace a previous SIP revision 

for this facility, which was submitted to EPA on December 13, 2012; with this letter we request 

withdrawal of that submittal. 
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. 

4. An electronic copy (CD) of the complete submittal. This electronic copy is an exact 

duplicate of the hard copy. 

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

DKP\kgs 

TEMPLA TES\SOURCE-SPECIFIC\PLNOO 

RACT\RICHMOND5\MDZ-SIP.DOC 

Enclosures 

Si Orely, ){J D~ j 

J6t1i&l /<i:&c}HJ\ 

David K. Paylor 
ENCLOSURE 1

COMMONWEALTH OF VIRGINIA

STATE IMPLEMENTATION PLAN REVISION

FOR

RICHMOND MAINTENANCE AREA

STATE OPERATING PERMIT FOR

MONDELĒZ GLOBAL LLC, INC.

(FORMERLY KRAFT FOODS)

HENRICO 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-RACT was Nabisco Brands (now 

Kraft Foods). Cookies, crackers, and pretzels are produced at this plant using two 

different dough processes: sponge-dough and straight-dough. In the sponge-dough 

process, doughs are formulated by yeast leavening; while in the straight-dough process, 

doughs are leavened chemically. The sources of VOC emissions at this plant are proofroom, ovens, and oil treatment facilities.

The facility underwent RACT analysis, and a federally-enforceable state operating permit 

was issued to the facility, which became effective on April 24, 1991. The permit was then 

submitted to EPA as a SIP revision, and approved into the Commonwealth’s SIP on 

March 6, 1992 (57 FR 8080). Because the Richmond area in which this facility is located 

has continuously been classified as either a nonattainment or a maintenance area, the 

RACT requirements remain in effect, and a change to the facility’s RACT permit 

necessitates a change to the SIP.

In 2006, Kraft made a number of modifications to its process that necessitated revisions 

to its RACT permit and therefore to the Commonwealth’s SIP. This permit was approved 

by EPA into Virginia's SIP on April 15, 2008 (73 FR 20175), with an effective date of May 

15, 2008.

Since then, Kraft made additional modifications to its process that necessitated further 

revisions to its RACT permit and therefore to the Commonwealth’s SIP. In an application 

received on August 31, 2012, Kraft Foods Global requested changes to the permit, 

including changes needed to accommodate replacement of the catalytic oxidizer with a 

more efficient regenerative thermal oxidizer. The change in the type of control device

would not affect VOC emissions because the destruction efficiency of the control device 

remained the same. At this time, the company's name changed from Kraft Foods to 

Mondelēz Global LLC, Inc. These permit revisions were submitted to EPA as a SIP 

revision on December 13, 2012.
3

Subsequently, the permit was updated to make it more streamlined by removing certain 

conditions (throughput and emission limits) and regulatory references (to malfunctions) 

that are not necessary to achieve the RACT requirements. These changes are in the 

interest of providing clarity, and will not result in any change in operations or emissions 

increase.

This document presents the RACT determination and analysis 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 B contains the demonstration of how the terms and conditions of the permit

meet the RACT requirements.

The SIP revision of December 14, 2012 is hereby withdrawn.

TEMPLATES\SOURCE-SPECIFIC\PLN01

RACT\RICHMOND5\MDZ-SIP-1.DOC
ATTACHMENT A

LEGALLY ENFORCEABLE MECHANISM (PERMIT)

TO ENSURE COMPLIANCE WITH

REASONABLY AVAILABLE CONTROL TECHNOLOGY REQUIREMENTS

FOR

Mondelēz Global LLC, Inc.

(formerly Kraft Foods)

Henrico County, Virginia

Registration No. 50703

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 February 11, 2014, 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 Natural Resources 

PIEDMONT REGIONAL OFFICE 

23060 

527-5!06 

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

requirements of 9 VAC 5-40-7390 of the Regulations of the Board and (ii) establishes control technology 

and other requirements for the control of volatile organic compound (VOC) emissions from the Mondelez 

Global, LLC- Richmond Bakery in the Richmond, Virginia Ozone Maintenance Area. These RACT 

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

permit 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 permit dated December 

11,2012. 

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 

Mondelez Global LLC 

Richmond Bakery 

6002 South Laburnum Avenue 

Richmond, VA 23231 

Registration No.: 50703 

State-County-Plant ID No.: 51-087-0083 

a commercial bakery 

6002 South Laburnum Avenue 

Richmond, VA 23231 

in accordance with the Conditions of this permit. 

Approved on February 11, 2014. 

·K}IM lvar~nter, P.E. 

Deputy Regional Director 

Permit consists of 5 pages. 
Mondelez Global LLG - Richmond Bakery 

Registration Number: 50703 

February 11,2014 

Page2 

PERMIT CONDITIONS -The regulatory reference or authority for each condition is listed in parentheses 

after each condition. 

PROCESS REQUIREMENTS - VOC Equipment List 

1. Equipment List- In accordance with 9 VAG 5-40-7370, the facility shall meet either the 

presumptive RAGT requirements of 9 VAG 5-40-7390 or the RAGT requirements determined by a 

RAGT determination in accordance with 9 VAG 5-40-7370 for the following equipment which are 

sources of VOG emissions and implemented through the remaining conditions of this permit: 

Unit Ref. Equipment I Operation 

No. Description 

Oven #1 Dough Oven 

Oven #2 Dough Oven 

Oven #3 Dough Oven 

Oven #4 Dough Oven 

Oven #5 Dough Oven 

Oven #6 Dough Oven 

Oven #8 Dough Oven 

Oven #9 Dough Oven 

(9 VAG 5-80-850) 

PROCESS REQUIREMENTS- VOC Emission Controls 

2. Emission Controls- Volatile organic compound (VOG) emissions from the Oven #1, when 

baking yeast dough, shall be controlled by design and proper operation of Oven #1, a permanent 

total enclosure (PTE) and a Regenerative Thermal Oxidizer (RTO) or equivalent control device as 

approved by DEQ, having a destruction efficiency of at least 95 percent on a mass basis. The RTO 

and/or equivalent control device shall be provided with adequate access for inspection and shall 

be in operation when the Oven #1 is operating. 

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

3. Total Enclosure- The (PTE) shall meet the following criteria: 

a. Any natural draft openings shall be at least 4 equivalent opening diameters from each VOG 

emitting point; 

b. The total area of all natural draft openings shall not exceed 5 percent of the surface area of 

the enclosure's four walls, floor and ceiling; 

c. The average facial velocity of air through the natural draft openings shall be at least 200 feet 

per minute and the direction of flow shall be into the enclosure. 

d. All access doors and windows shall be closed during routine operation of the Oven #1. 

e. All of the exhaust gases from the enclosure shall be directed to the RTO or equivalent control 

device. 

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

4. Monitoring Devices- The RTO or equivalent control device shall be equipped with a device to 

continuously measure and record the combustion zone temperature on a 5-minute interval. Each 

monitoring device shall be installed, maintained, calibrated, and operated in accordance with 

approved procedures which shall include, as a minimum, the manufacturer's written requirements 

or recommendations. Each monitoring device shall be provided with adequate access for 

inspection and shall be in operation when Oven #1 is operating. 

(9 VAG 5-40-7370 and 9 VAG 5-80-850) 
PROCESS REQUIREMENTS - Operational Limitations 

Mondelez Global LLC - Richmond Bakery 

Registration Number: 50703 

February 11, 2014 

Page3 

5. Regulations of the Board - Mondelez Global LLC (Mondelez) shall comply with all applicable 

Regulations of the Board including the requirements for monitoring, notification, record keeping, 

reporting, maintenance, and malfunction. Mondelez agrees that this permit is not construed to mean 

that its operation is automatically in compliance with all aspects of the Regulations of the Board. 

Compliance with all air pollution regulations must be a continuing, full time effort. 

(9 VAC 5-80-850) 

6. Oil Type- The type of oil used in the oil treatment facilities shall be limited to only vegetable oils. 

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

7. Dough Type- The feed to Oven Numbers 2, 3, 4, 5, 6, 8, and 9 shall not contain any yeast dough. 

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

8. Temperature -When baking yeast dough in Oven #1, Mondelez shall demonstrate continued 

compliance with the destruction efficiency specified in Condition 2 by maintaining the control device 

minimum combustion zone temperature and residence time, established during the initial or most 

recently DEQ approved performance test. 

(9 VAC 5-80-850) 

9. Monitoring Device Observation -The device used to measure the combustion zone temperature 

from the RTO shall be observed by the permittee with a frequency sufficient to ensure good 

performance of the RTO. The permittee shall keep a log of the observations of the combustionmonitoring device. 

(9 VAC 5-80-850) 

TESTING 

10. Emissions Testing - The 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 VAC 5-50-30 F and 9 VAC 5-80-850) 

RECORDS 

11. 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 Director, Piedmont Regional Office. These records shall 

include, but are not limited to: 

a. Log of observations of the combustion temperature monitoring device on the RTO. 

b. Results of all stack tests, visible emission evaluations and performance evaluations. 

The records required by this permit shall be maintained by Mondelez for a minimum of the most 

recent three year period and made available for review and inspection by representatives of the 

Department. 

(9 VAC 5-80-850) 
NOTIFICATIONS 

Mondelez Global LLC - Richmond Bakery 

Registration Number: 50703 

February 11, 2014 

Page4 

12. Initial Notifications- The permittee shall furnish written notification to the Piedmont Regional 

Office of the intention to replace the current control device with an equivalent control device. The 

notification shall include information documenting the emissions from Oven #1 as a result of the 

control device replacement.. 

A copy of the written notification shall be sent to: 

Associate Director 

Office of Air Enforcement and Compliance Assistance (3AP20) 

U.S. Environmental Protection Agency 

Region Ill 

1650 Arch Street 

Philadelphia, PA 19103-2029 

(9 VAC 5-50-50 and 9 VAC 5-80-850) 

13. Monitoring Notification - Mondelez shall record and notify Director, Piedmont Region in writing 

within ten days of the date and time for each period during which any monitoring system is 

inoperative (except for calibration), the nature of the system problems, and the repairs or 

adjustments that were made. 

(9 VAC 5-80-850) 

GENERAL CONDITIONS 

14. 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, regulatory 

or statutory requirement. Furthermore, this approval to operate shall not relieve Mondelez of the 

responsibility to comply with all other local, state and federal regulations, including permit regulations. 

(9 VAC 5-80-800 D and 9 VAC 5-80-820 F) 

15. 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 VAC 5-80-800 C.2 and 9 VAC 5-80-820 F) 

16. Permit Modification- The Board may revise (modify, rewrite, change or amend) or repeal this 

permit with the consent of Mondelez, for good cause shown by Mondelez , or on its own motion 

provided approval of the revision or repeal is accomplished in accordance with 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 of Implementation Plans). 

(9 VAC 5-80-960 and 9 VAC 5-80-1000) 

17. Failure to Comply- Failure by Mondelez 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 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 VAC 5-80-910, and 9 VAC 5-80-1010) 

18. 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; 
Mondelez Global LLC - Richmond Bakery 

Registration Number: 50703 

February 11, 2014 

PageS 

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 VAC 5-170-130 and 9 VAC 5-80-850) 

19. 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 Director, Piedmont Region of the change of ownership within 30 days of the transfer. 

(9 VAC 5-80-940) 

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

which it applies. 

(9 VAC 5-80-860 D) 
ATTACHMENT B

DEMONSTRATION OF COMPLIANCE WITH

REASONABLY AVAILABLE CONTROL TECHNOLOGY REQUIREMENTS FOR

Mondelēz Global LLC, Inc.

(formerly Kraft Foods)

Henrico County, Virginia

Registration No. 50703
COMMONWEALTH OF VIRGINIA 

Department of Environmental Quality 

Piedmont Regional Office 

STATEMENT OF LEGAL AND FACTUAL BASIS 

Mondelez Global LLC - Richmond Bakery 

Richmond, Virginia 

Permit No. PR050703 

The Department of Environmental Quality (DEQ) has prepared a State Operating Permit for Mondelez 

Global LLC- Richmond Bakery for a State Implementation Plan (SIP) revision to make the conditions of 

the RACT requirements state and federally enforceable. 

Engineer/Permit Contact: ~ ~ fZ""= 

Jennif oeffner 

(804) 527-5123 

Date: &ju /1 f 

I 

Deputy Regional 
I. Facility Information 

Permittee/Facility 

Mondelez Global LLC - Richmond Bakery 

6002 South Laburnum Avenue 

Richmond, VA 23231 

County-Plant Identification Number: 51-087-00083 

II. Source Description 

NAICS Code: 311919- Snack Food Manufacturing 

Mondelez Global LLC - Richmond Bakery 

PRO 50703 

Statement of Basis 

Page 2 

Mondelez Global LLC - Richmond Bakery is a commercial bakery that produces a variety of baked 

commodities such as Wheat Thins, Ritz Crackers, Nilla Wafers, Cheese Nips, Oreos, and Chips 

Ahoy. 

The facility is not a Title V major source. This source is located in an attainment area for all criteria 

pollutants, is in an ozone maintenance area, and is not a PSD source. The facility is currently 

permitted under a State Operating Permit issued on February 22, 2012. The last air inspection was 

conducted at the facility on August 1, 2013 and the facility was found to be in compliance. 

Ill. Summary of Changes to RACT Requirements 

A permit was issued to Mondelez Global LLC (Mondelez) by DEQ on September 19, 2007 (2007 

permit) and was superseded with the issuance of a permit on December 11, 2012 (2012 permit). 

This permit contained the RACT for the control of VOC emissions and specified certain operating 

conditions for the facility's ovens. In applications received on August 31, 2012 and on July 12, 2013, 

Mondelez requested changes to the permit including the throughput and emission limits for Oven #1. 

DEQ has updated the permit to make it more streamlined by removing other conditions (throughput 

and emission limits) and regulatory references (to malfunctions) that are not necessary to achieve 

the RACT requirements. Below are the facility's requests, DEQ's responses, and the changes to the 

permit that have resulted. 

1. Revise Condition 1 

The equipment description is being changed from listing specific types of dough to dough oven, 

the maximum rated capacities are being removed and the fuel type utilized by the ovens is being 

removed. The changes to this condition do not affect what has been established as RACT. 

Change: Condition 1 equipment table has been updated to the following: 

Unit Ref. Equipment I Operation 

No. Description 

Oven #1 Dough Oven 

Oven #2 DouQh Oven 

Oven #3 Dough Oven 

Oven #4 Dough Oven 

Oven #5 DouQh Oven 

Oven #6 Dough Oven 

Oven #8 Dough Oven 

Oven #9 DouQh Oven 
Mondeh§z Global LLC - Richmond Bakery 

PRO 50703 

Statement of Basis 

Page 3 

2. Replacement of the catalytic thermal oxidizer (CTO) with a regenerative thermal oxidizer 

(RTO) 

Mondelez: Mondelez stated that the replacement of the CTO with the RTO will benefit the 

environment and it will be of commercial importance to Mondelez. Mondelez requested this 

change in part based on the current state of the CTO due to its age, despite proper maintenance 

including the replacement of the catalyst in 2011. The request is also based on the fact that the 

RTO will control VOC emissions at the same levels as the CTO, because it has a destruction 

efficiency of 95%. Mondelez requested that any references to the CTO or the catalyst be 

removed from the 2007 permit Conditions 2, 4, 8, 13, and 16. 

DEQ: RACT for Oven 1 while baking sponge-dough was initially determined to be control of VOC 

emissions in part through the use of a catalytic incinerator having a destruction efficiency of 95%. 

While Mondelez is requesting a change in the type of control device to be used to, the emissions 

will not be affected as a result of the change because the destruction efficiency of the control 

device has remained the same. DEQ finds the request to be acceptable. 

Changes that occurred in the 2012 permit: All references to the CTO, the catalyst, and 

language associated with the CTO and catalyst were removed from permit Conditions 2, 4, 13 

(currently Condition 11 ). 

2007 permit Condition 8: entire condition was deleted based on a separate request by Mondelez. 

Further details about the condition deletion are discussed below in item 9. 

2007 permit Condition 16 (2012 permit Condition 19): entire condition was deleted. Further 

details about the condition deletion are described below in item 19. 

3. Replace references to "sponge dough" with yeast dough 

Mondelez: Mondelez requested that any references to "sponge dough" be replaced with yeast 

dough in the 2007 permit Conditions 1, 2, 3, 4, 7, 8, 9, 10, 13, and 16. 

DEQ: The Consent Order that was written to establish RACT included a definition section. 

Sponge-dough was defined in the Consent Order as, dough formulated by yeast leavening. 

Because the name change has no affect on the RACT determination and the name change 

clarifies the type of dough, DEQ finds the change acceptable. 

Changes that occurred in the 2012 permit: All references to "sponge dough" were replaced 

with yeast dough in permit Conditions 2, 3, 4, 7, and 13 (currently Condition 11 ). 

Condition 1: was updated as described above in item 1. 

2007 permit Condition 8: entire condition was deleted based on a separate request by Mondelez. 

Further details about the condition deletion are discussed below in item 9. 

2007 permit Condition 9 (2012 permit Condition 10): was updated as described below in item 10. 

2007 permit Condition 10 (2012 permit Condition 11 ): was updated as described below in item 11. 

2007 permit Condition 16 (2012 permit Condition 19): entire condition was deleted. Further 

details about the condition deletion are described below in item 19. 

4. Replace references to "straight dough" with non-yeast dough 

Mondelez: Mondelez requested that any references to "straight dough" be replaced with non-
yeast dough in 2007 permit Conditions 1, 7, 10, and 13. 

Mondelez Global LLC - Richmond Bakery 

PRO 50703 

Statement of Basis 

Page4 

DEQ: The Consent Order that was written to establish RACT included a definition section. 

Straight dough was defined in the Consent Order as, dough leavened chemically in the absence 

of yeast. Because the name change has no affect on the RACT determination and the name 

change clarifies the type of dough, DEQ finds the change acceptable. 

Changes that occurred in the 2012 permit: All references to "straight dough" were replaced 

with non-yeast dough in permit Conditions 7 and 13, (currently Condition 11 ). 

Condition 1: was updated as described above in item 1. 

2007 permit Condition 10 (2012 permit Condition 11 ): was updated as described below in item 11. 

5. Remove "propane" 

Mondelez: Mondelez requested that "propane" be removed from 2007 permit Condition 1 as a 

fuel for the ovens. 

DEQ: The removal of propane as a type of fuel to be utilized by the ovens has no affect on the 

RACT determination therefore DEQ finds the change to be acceptable. 

Change: Condition 1 was updated as described above in item 1. 

6. Revise language in Condition 2 

Mondelez: Mondelez requested 2007 permit Condition 2 to be revised as follows: " ... when baking 

yeast containing dough, shall be controlled by the use of a control device that achieves a destruction 

efficiency of at least 95 percent on a mass basis. The device shall be provided with adequate 

access for inspection and shall be in operation when the Oven #1 is operating." 

DEQ: DEQ recognizes that Mondelez would like to have flexibility with regard to replacement of 

the control device in the future so that Mondelez could replace the control device if there were 

operational issues with it. Part of the initial RACT determination was the control of VOC 

emissions through the use of a catalytic incinerator having a destruction efficiency of 95%. The 

item of significance in this determination is the extent that the emissions are controlled, 95%, not 

the type of control. Not listing the specific control is not a relaxation of the RACT since the 

requirement will stipulate that the control device must have a destruction efficiency of 95% 

therefore, the emissions released to ambient air would remain the same. The requirements of 9 

VAC 5-40-7370 will be met with the revised language of this Condition. References to the control 

device in Condition 2 of the permit that will be revised to list the RTO as the control device but it 

will also include language that will allow the replacement of the RTO by an equivalent control 

device in the event that the RTO would need to be replaced. Should the RTO need to be 

replaced, Mondelez will be required to go through all of the steps of permitting with DEQ, as 

indicated in the condition, "as approved by DEQ". However, this permitting process will not 

require this permit to be opened and/or updated. DEQ will only approve the replacement once it 

has determined that the control device will have a control efficiency/destruction efficiency of 95%. 

A notification requirement regarding the replacement of the control device was added to the 2012 

permit and is discussed in detail below in item 17. The condition was updated to include that 

VOC emissions will be controlled by design and proper operation of Oven #1. This was added 

because it was part of the initial RACT determination. The condition was also updated to include 

that VOC emissions will be controlled by a permanent total enclosure (PTE). Further explanation 

of this is described below in item 7. 
Mondelez Global LLC - Richmond Bakery 

PRO 50703 

Statement of Basis 

Page 5 

Change that occurred in the 2012 permit: Condition 2 has been revised as follows: "Volatile 

organic compound (VOC) emissions from the Oven #1, when baking yeast dough, shall be 

controlled by design and proper operation of Oven #1, a permanent total enclosure (PTE) and a 

Regenerative Thermal Oxidizer (RTO) or equivalent control device as approved by DEQ, having a 

destruction efficiency of at least 95 percent on a mass basis. The RTO and/or equivalent control 

device shall be provided with adequate access for inspection and shall be in operation when the 

Oven #1 is operating." 

7. Revise language in Condition 3 

RACT for Oven 1 while baking sponge-dough was initially determined to be control of VOC 

emissions in part by a PTE. Condition 3 included this requirement in the permit. Condition 3 also 

required that the PTE meet the criteria presented in Appendix A. Appendix A described the 

requirements of test method 204. When the initial RACT determination was made test method 204 

for a PTE was not an approved test method and, therefore, Appendix A was incorporated in the 

determination. The original Appendix A has been removed from the permit and the permit has been 

updated to be consistent with the current permit boilerplate. The requirements that were detailed in 

the original Appendix A now appear in Condition 3. The requirement of a PTE as a method of VOC 

emissions control has been incorporated in Condition 2. 

Changes that occurred in the 2012 permit: 

Condition 2 was updated and can be referenced above in item 6. 

Condition 3 states the following: "The (PTE) shall meet the following criteria: a. Any natural draft 

openings shall be at least 4 equivalent opening diameters from each VOC emitting point; b. The 

total area of all natural draft openings shall not exceed 5 percent of the surface area of the 

enclosure's four walls, floor and ceiling; c. The average facial velocity of air through the natural 

draft openings shall be at least 200 feet per minute and the direction of flow shall be into the 

enclosure. d. All access doors and windows shall be closed during routine operation of the Oven 

#1. e. All of the exhaust gases from the enclosure shall be directed to the RTO or equivalent 

control device." 

8. Revise language in Condition 4 

Mondelez: Mondelez requested 2007 permit Condition 4 to be revised as follows: "Mondelez shall 

install, calibrate, operate, and maintain monitoring devices that continuously measure the average 

temperature of any control device treatment chamber(s) on a 5-minute interval during baking of 

yeast dough in Oven #1 and shall comply with the following requirements: Each continuous 

monitoring device shall be calibrated annually and have an accuracy of ±1 percent of the 

temperature being measured in Celsius degrees or± 0.5°C, whichever is greater." 

DEQ: Monitoring the average temperature from a control device is not consistent with permits 

that have been issued by DEQ. DEQ suggested applying its boilerplate language for monitoring 

devices associated with RTOs. This language will give Mondelez more flexibility with the 

operating temperatures of the RTO than the language that it had proposed. Mondelez agreed to 

DEQs suggestion. Condition 4 has also been updated to be consistent with the language 

regarding control devices described in Condition 2. 

Change that occurred in the 2012 permit: Condition 4 was revised as follows: "The RTO or 

equivalent control device shall be equipped with a device to continuously measure and record the 

combustion zone temperature on a 5-minute interval. Each monitoring device shall be installed, 

maintained, calibrated, and operated in accordance with approved procedures which shall include, 

as a minimum, the manufacturer's written requirements or recommendations. Each monitoring 
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device shall be provided with adequate access for inspection and shall be in operation when Oven 

#1 is operating." 

9. Remove 2007 permit Condition 8 

Mondelez: Mondelez requested that 2007 permit Condition 8 be removed from the permit based 

on the following information: The fan installed at the time of the original RACT did not have a 

Variable Frequency Drive (VFD) and had a specific set point. The new RTO regulates the flow 

based on its internal controls, so this no longer is required. The manufacturer guarantees that 

destruction is performed at a specific temperature. The manufacturer indicated this in their design 

manual and in their experience with permitting in numerous states has indicated they have never 

seen that condition apply to an RTO or their RTOs. Additionally, flow is not a required monitoring 

condition in other Mondelt§z facilities or most other applications of an RTO in other industries. 

DEQ: DEQ finds the request acceptable because compliance will be demonstrated by the control 

device maintaining the minimum combustion zone temperature and residence time as detailed in 

Condition 9 of the permit. No additional measures are required to demonstrate compliance with 

the control device destruction efficiency. The requirement of the exhaust gas flow rate from Oven 

#1 was also a method of determining compliance with Oven #1 operating as a PTE. The 

performance test that was conducted on the PTE and compliance was confirmed (see item 14 

below). All of the criteria for the PTE are being met and the negative pressure into the oven is 

maintained through the permanent setting of exhaust fans, which cannot be adjusted. Based on 

this information the VOC capture efficiency is assumed to be 100% and capture efficiency does 

not need to be measured to demonstrate compliance. 

Change that occurred in the 2012 permit: The 2007 permit Condition 8 was removed from the 

permit. 

10. Remove 2012 permit Condition 10 

The throughput limit of yeast dough products for Oven #1 is being removed from the permit. DEQ 

determined that this requirement is not needed for RACT, and in the interest of clarity, has removed 

it. Although this condition is being removed from this permit, it continues to be a requirement in 

the current State Operating Permit for Mondelez. 

Change: The 2012 permit Condition 10 has been removed from the permit. 

11. Remove 2012 permit Condition 11 

The throughput option condition is being removed from the permit. DEQ has determined that this 

requirement is not needed for RACT, and in the interest of clarity, has removed it. 

Change: The 2012 permit Condition 11 has been removed from the permit. 

12. Remove 2012 permit Condition 12 

The emission limit condition is being removed from the permit. DEQ has determined that this 

requirement is not needed for RACT, and in the interest of clarity, has removed it. Although this 

condition is being removed from this permit, it continues to be a requirement in the current State 

Operating Permit for Mondelez. 

Change: The 2012 permit Condition 12 has been removed from the permit. 
13. Revise language in 2007 permit Condition 12 

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Mondelez: Mondelez requested 2007 permit Condition 12 to be revised as follows: "When baking 

yeast dough in Oven #1, Mondelez shall demonstrate continued compliance with the destruction 

efficiency specified in Condition 2 by maintaining the average control device treatment chamber 

temperature, on a 5-minute interval basis, at not less than 5°F below that established during the 

most recent performance test. Mondelez shall test the destruction efficiency of the control device 

upon initial operation to demonstrate that the device is functioning properly and in compliance with 

Condition 2. The facility shall maintain the ability to perform additional testing to modify the operating 

parameters at any time. The facility shall furnish written notification to the Director, Piedmont Region 

of any testing and testing results." 

DEQ: A Condition for continued compliance was included in the permit as Condition 8. Maintaining 

the average control device treatment chamber temperature as a method to demonstrate 

continued compliance is not consistent with permits that have been issued by DEQ. DEQ 

suggested applying its boilerplate language for the method to demonstrate continued compliance 

from an RTO. This language will give Mondelez more flexibility with the operating temperatures of 

the RTO than the language that it had proposed. Mondelez agreed to DEQ's suggestion. The 

annual testing condition that was described in the 2007 permit Condition 12 has been removed 

from the permit because it was based on the previous control device. Conditions for emission 

testing were included in the 2012 permit Conditions 13 and 14. 2012 permit Condition 13 

(currently Condition 10) is a general emission testing condition. 2012 permit Condition 14 

required an initial performance test for the RTO. 

Changes that occurred in the 2012 permit: 

Condition 8 states the following: "When baking yeast dough in Oven #1, Mondelez shall 

demonstrate continued compliance with the destruction efficiency specified in Condition 2 by 

maintaining the control device minimum combustion zone temperature and residence time, 

established during the initial or most recently DEQ approved performance test." 

2012 permit Condition 13 (currently Condition 1 0) states the following: "The facility shall be 

constructed so as to allow for emissions testing upon reasonable notice at any time, using 

appropriate methods. Sampling ports shall b€1 provided when requested at the appropriate 

locations and safe sampling platforms and access shall be provided." 

2012 permit Condition 14 stated the following: "Initial performance tests shall be conducted for 

VOC from the RTO using reference Method 25 to determine compliance with the destruction 

efficiency contained in Condition 2. Initial performance tests shall be conducted for VOC from the 

PTE using reference Method 204 to determine compliance with the emissions control contained in 

Condition 3. Additional performance tests may be conducted for VOC from a control device 

equivalent of the RTO using the appropriate method to determine compliance with the destruction 

efficiency contained in Condition 2. The tests shall be performed, and demonstrate compliance 

within 60 days after achieving the maximum production rate at which the facility will be operated 

but in no event later than 180 days after start-up of the permitted facility. Start-up is defined as 

when the RTO at the Mondelez Global LLC facility located at 6002 South Laburnum Ave., 

Richmond, Virginia, becomes operable. Tests shall be conducted and reported and data reduced 

as set forth in 9 VAC 5-50-30 and the test methods and procedures contained in each applicable 

section or subpart listed in 9 VAC 5-50-410. The details of the tests are to be arranged with the 

Director, Piedmont Region. The permittee shall submit a test protocol at least 30 days prior to 

testing. One copy of the test results shall be submitted to the Director, Piedmont Region within 60 

days after test completion and shall conform to the test report format enclosed with this permit 

(Appendix A)." The requirements of 2012 permit Condition 14 have since been completed and 

therefore, the condition is being removed as described in item 14 below. 
14. Remove 2012 permit Condition 14 

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The stack test condition is being removed from the permit. The requirements of this condition 

have been completed. The RTO stack test and the test associated with the PTE were conducted 

on June 25, 2013. The test data was submitted on August 23, 2013. The test data was reviewed 

and compliance was confirmed. 

Change: The 2012 permit Condition 14 has been removed from the permit. 

15. Revise 2012 permit Condition 15 

Conditions 15.a and bare being removed from the permit. Condition 15.a was a recordkeeping 

condition that correlated with the 2012 permit Condition 10, which has been removed from the permit 

as described in item 10 above. Condition 15.b was reviewed and it has been determined that it is not 

needed for RACT, and in the interest of clarity, are therefore removing it. Condition 15.d is being 

revised to require results of tests rather than dates of tests and to omit the reference to the testing 

condition (2012 permit Condition 14) that has been removed from the permit as discussed in item 14 

above. 

Changes: The 2012 permit Conditions 15.a and b have been removed from the permit. 

The 2012 permit Condition 15.d, currently Condition 15.b in part states the following: "Results of 

all stack tests, visible emission evaluations and performance evaluations". 

16. Revise language in 2007 permit Condition 16 

Mondelez: Mondelez requested 2007 permit Condition 16 to be revised as follows: " ... a. The 

average control device treatment chamber temperature, when baking yeast dough in Oven #1 is 

more than 28°C below the average temperature demonstrated during the most recent performance. 

b. During baking of yeast dough, Oven #1 treatment device fails or malfunctions and may have 

caused excess emissions for more than 1 hour." 

DEQ: The proposed language would allow for fluctuations from what will be demonstrated as 

compliance during the stack test. DEQ suggested updating the condition to be consistent with 

Condition 8 of the permit. Mondelez agreed to DEQs suggestion. The condition was revised to 

reflect the current control device. 

Changes that occurred in the 2012 permit: 

2012 permit Condition 19 (2007 permit Condition 16) states the following: " ... a. When the control 

device minimum combustion zone temperature and residence time, when baking yeast dough in 

Oven #1 (demonstrated during the most recent performance test) are not being met. b. During 

baking of yeast dough, Oven #1 or control device fails or malfunctions and may cause excess 

emissions for more than 1 hour." Since the issuance of the 2012 permit this condition has been 

reviewed and is being removed from the permit. Further details are described below in item 19. 

17. Initial notification condition 

An initial notification condition was added to the 2012 permit for the actual date of construction of the 

RTO, the actual start-up date for the RTO, and for the replacement of the current control device. 

2012 permit Condition 16 stated the following: "The permittee shall furnish written notification to 

the Piedmont Regional Office of: a. The actual date on which construction of the RTO 

commenced within 30 days after such date. b. The actual start-up date of the RTO within 15 
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days after such date. c. The intention to replace the current control device with an equivalent 

control device. The notification shall include information documenting the emissions from Oven 

#1 as a result of the control device replacement" 

Revise 2012 permit Condition 16 

The initial notification 2012 permit Condition 16.a and b associated with the RTO are being removed 

from the permit The requirements of this condition have been completed. The actual date of 

construction for the RTO was December 20, 2012. The actual start-up date of the RTO was May 

10, 2013. 

Changes: 

The 2012 permit Conditions 16.a and b have been removed from the permit. 

18. Remove 2012 permit Condition 17 

The production notification condition is being removed from the permit because it correlated with the 

2012 permit Condition 10, which has been removed from the permit as described in item 10 above. 

Change: The 2012 permit Condition 17 has been removed from the permit 

19. Remove 2012 permit Condition 19 

The malfunction notification condition is being removed from the permit because it is not directly 

relevant to RACT. Mondelez is required by the Regulations of the Board to notify DEQ of 

malfunctions of affected facilities or related air pollution control devices. 

Change: The 2012 permit Condition 19 has been removed from the permit. 

20. Condition 9 

A monitoring device observation condition was added to the 2012 permit to ensure good 

performance of the RTO. A record keeping condition regarding the observations was also added to 

the permit 

Condition 9 states the following: "The device used to measure the combustion zone temperature 

from the RTO shall be observed by the permittee with a frequency sufficient to ensure good 

performance of the RTO. The permittee shall keep a log of the observations of the combustionmonitoring device." 

Condition 11.a states the following: "Log of observations of the temperature monitoring device on 

the RTO." 

Other changes made to the permit: 

The date of the permit to be superseded has been updated. 

IV. Emission Unit(s)/Process Description(s) 

The conditions of the RACT requirements pertain to the specific units below: 

Unit Ref. Equipment I Operation 

No. Description 

Oven #1 Dough Oven 
Oven #2 

Oven #3 

Oven #4 

Oven #5 

Oven #6 

Oven #8 

Oven #9 

V. Regulatory Review 

DouQh Oven 

Dough Oven 

Dough Oven 

Dough Oven 

Dough Oven 

Dough Oven 

Dough Oven 

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9 VAG 5 Chapter 80, Article 5- State Operating Permit Review 

Per 9 VAG 5-80-800 C.2.b, DEQ may issue a State Operating Permit (SOP) to establish a sourcespecific emission standard or other requirement necessary to implement the federal Clean Air Act or 

the Virginia Air Pollution Control Law. The intent of this SOP is a source specific State 

Implementation Plan (SIP) Revision to make the conditions of the RACT requirements state and 

federally enforceable. 

9 VAG 5 Chapter 80, Part II, Article 6- Minor New Source Review 

Mondelez is not proposing to construct or modify any emission unit. Therefore, minor new source 

review is not required. 

9 VAG 5 Chapter 80, Article 8- PSD Major New Source Review 

This facility is not a PSD major source. 

9 VAG 5 Chapter 80, Article 9- Non-attainment Review 

This facility is not a non-attainment major source. 

40 CFR Part 60- NSPS 

No applicable NSPS standards apply to this facility. 

40 CFR Part 61 - NESHAPS 

No applicable NESHAP standards apply to this facility. 

40 CFR Part 63 - MACT 

No applicable MACT standards apply to this facility. 

VI. Summary of Emissions 

The emissions at the facility have not changed with this SOP SIP Revision. 

VII. Boilerplate Deviations 

There were no boilerplate deviations with this permit. 

VIII. Compliance Demonstration 

The initial performance tests associated with the RTO and the PTE have been completed. No new 

compliance demonstrations were added with this SOP SIP Revision. 

IX. Title V Review- 9 VAC 5 Chapter 80, Part II, Article 1 

Mondelez Global LLC - Richmond Bakery is not a major source and is therefore not subject to the 

Title V program. 
X. Background Findings for RACT Requirements 

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1. In the 1985 SIP revision and again by letter of May 10, 1989, DEQ made a commitment to establish 

emission standards in accordance with EPA policy requiring RACT for all non-CTG major stationary 

sources of VOC emissions in Richmond area in order to diminish or abate causes of air pollution, 

especially ozone in Richmond area. Accordingly, this permit will be submitted to EPA as a revision to 

the SIP and upon approval become federally enforceable. 

2. Mondelez was determined by DEQ to be a non-CTG major stationary source of VOC emissions in 

the Richmond area. 

3. On December 21, 1989 Mondelez met with DEQ to discuss the RACT determination for the affected 

facility. 

4. The feed to Oven Numbers 2, 3, 4, 5, 6, 8, 9, and 10 contains only non-yeast dough and does not 

contain any yeast-dough. 

5. Uncontrolled VOC emissions from the baking of yeast-dough in Oven Number 1 were estimated to 

be 261 tons per year. 

6. Uncontrolled VOC emissions from the baking of non-yeast dough were estimated to be less than 1 

ton per year for each oven. 

7. Uncontrolled VOC emissions from the proof-room were estimated to be 0.3 ton per year. 

8. According to an August 21, 1990 policy memo "Interpretation of VOC Definition as Applied to 

Vegetable Oil" from EPA's Office of Air Quality Planning and Standards, vegetable oil emissions are 

not considered as VOC for the purpose of control programs for attaining the national ambient air 

quality standards for ozone. 

9. RACT for Oven Number 1, when baking yeast-dough, is determined to be the control of VOC 

emissions as described below: 

a. The design and proper operation of the oven that meet criteria of a PTE as detailed in 

condition 3. 

b. The use of a RTO or equivalent control device having a VOC destruction efficiency of at 

least 95 percent on a mass basis. 

10. RACT for Oven Number 1, when baking non-yeast dough, is determined to be no control. 

11. RACT for Oven Numbers 2, 3, 4, 5, 6, 8, and 9 is determined to be a limit on their baking processes 

to only non-yeast dough. 

12. RACT for the proof-room is determined to be no control. 

13. RACT for the oil treatment facilities is determined to be a limit on the type of oil used to only 

vegetable oils. 

14. Oven Number 7 is regulated by a new source permit and, therefore, it is not subject to this permit. 
XI. Public Participation 

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Notice of the draft State Operating Permit and the proposed revision to the Virginia SIP inviting 

public comment was placed in the Style Weekly newspaper on January 8, 2014. The public 

comment period began January 8, 2014 and ended February 10, 2014. A public hearing was held 

on February 4, 2014 and in accordance with the applicable provisions of 9 VAC 5-80-1020 and 9 

VAC 5-170-100. 

The draft documents were sent to EPA on January 3, 2014. No comments were received from 

the public or EPA and no one attended the public hearing. 

XII. Recommendations 

Recommend approval of the State Operating Permit. 

Attachment: 

Appendix A- Reasonably Available Control Technology Determination 
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APPENDIX A 

Commonwealth of Virginia 

State Air Pollution Control Board 

State Implementation Plan Revision for Richmond Maintenance Area 

Reasonably Available Control Technology Determination for 

Mondelez Global LLC 

A. INTRODUCTION 

Virginia is required to adopt and enforce a plan to attain and maintain the federal ambient air quality 

standards throughout the state. The Richmond area, although currently attaining the ozone air 

quality standard and classified as maintenance area, has fluctuated between attainment and 

nonattainment of the ozone standard in the past. In 1985 a plan to attain and maintain the ozone air 

quality standard in the Richmond Ozone Nonattainment Area was adopted which demonstrated 

attainment by the end of 1987. However, the plan was never acted upon by the U.S. Environmental 

Protection Agency (EPA) and the Richmond area, failed to meet the ozone air quality standard by the 

end of 1987. Therefore, continuing efforts were needed to bring the Richmond area into attainment 

for ozone. 

The Federal Clean Air Act mandated that all such plans require the implementation of all reasonably 

available control measures (RACM). EPA is given the responsibility to determine, in general, those 

measures. EPA defined the RACM for the Richmond nonattainment situation; one of which was to 

require emission controls for presently uncontrolled major stationary sources. Thus, in order to have 

a fully approvable plan, control methods for this category of sources must be analyzed and, if found 

to be reasonable, implemented. 

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 [>100 tons per year (TPY) potential] for 

which EPA had not issued Control Techniques Guidelines (non-CTG). 

EPA defined RACT as 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. 

RACT may be a technology that has been applied to similar, but not necessarily identical, source 

categories. It is not intended that extensive research and development be conducted before a given 

control technology can be applied to the source. This does not, however, preclude a short term 

evaluation program to permit the application of a given technology to a particular source. The latter 

effort is an appropriate technology forcing aspect of RACT. If RACT exists, then a legally 

enforceable means must be adopted to require the necessary emission reductions. 

Initially, based on 1983 VOC emissions, the following sources were identified to be major non-CTG 

sources in the Richmond area and the RACT determinations were prepared and submitted by the 

Department of Environmental Quality (DEQ) to EPA as part of the 1985 plan: 

E. I. DuPont and Company (Textile Polymer Fibers) 

William Byrd Press (Graphic Arts) 

Philip Morris USA--2 plants (Tobacco Processing) 

Reynolds Metals Company (Foil Processing) 
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Because EPA had indicated that this was a continuing on-going activity, Mondelez Global LLC 

(Cookie Bakery) was identified since 1985 as major non-CTG source in the Richmond area. 

This document presents the RACT determination and analysis for the control of VOC emissions 

from Mondelez Global LLC (Mondelez) plant located in Henrico County, Virginia. Where 

appropriate, legally enforceable mechanisms have been drafted to ensure compliance with the 

RACT requirement. 

When Mondelez was initially determining RACT alternatives it considered seven different controls. 

They were catalytic incineration, thermal incineration, carbon adsorption, scrubbing, condensation, 

bio-filters and process modification. At the time a similar RACT study had been completed by the 

Bay Area Air Quality Management District (BAAQMD) for control of ethanol emissions from large 

commercial bakery ovens. The study evaluated all seven control alternatives. BAAQMD found that 

incineration was the only feasible control alternative. DEQ concluded that the same finding would 

apply to Oven No. 1 at Mondelez because the process and emissions were fundamentally similar for 

bread baking ovens and Oven No. 1 at Mondelez. 

Mondelez had proposed to install a catalytic incinerator with a vendor guaranteed destruction 

efficiency of at least 95% to be considered as RACT. This RACT proposal was approved and 

memorialized in a Consent Agreement and Order which was subsequently incorporated into the SIP. 

At this time Mondelez is proposing that the catalytic thermal oxidizer (CTO) be replaced with a 

regenerative thermal oxidizer (RTO) and be considered as RACT. Mondelez has stated that the 

replacement of the CTO with the RTO will benefit the environment and it will be of commercial 

importance to Mondelez. Mondelez requested this change in part based on the current state of 

the CTO due to its age, despite proper maintenance including the replacement of the catalyst in 

2011. The request is also based on the fact that the RTO will control VOC emissions at the same 

levels as the CTO, because it has a destruction efficiency of 95%. Additionally, in interest of 

clarity, DEQ has updated the permit by removing certain conditions that are not necessary to 

achieve the RACT requirements (throughput and emission limits) and reference to malfunction 

provisions that are already covered in Mondelez's other operating permit and governed by 

Regulations of the Board. Because these provisions are permitted and regulated elsewhere, 

these revisions to the RACT-specific permit do not relieve Mondelez of its responsibility to meet all 

requirements of all of permits issued by DEQ as well as all Regulations of the Board. 

B. PROCESS DESCRIPTION 

1. General: Mondelez produces cookies, crackers, and pretzels at this plant. All physical mixing and 

blending of ingredients, proofing, remixing, handling of the doughs, baking, oil treatment, post 

conditioning, and packaging is performed mechanically without manual handling. 

The plant uses two different dough processes: yeast-dough and non-yeast dough. In the yeastdough process, doughs are formulated by yeast leavening; while in the non-yeast dough process, 

doughs are leavened chemically in the absence of yeast. 

The potential sources of VOC emissions at this plant are proof-room, ovens, and oil treatment 

facilities. They are described below. 

2. Proof-room: The doughs are proofed in an enclosed room (proof-room) under tightly controlled 

temperature and humidity. The yeast-doughs are proofed for about 24 hours, while the non-yeast 

doughs are proofed for about one hour. 
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3. Ovens: The primary source of VOC emissions from this source category is ovens that bake yeastdoughs. There are nine existing baking ovens at this plant, of which only one oven (Oven No. 1) 

bakes yeast-doughs. The rest of the eight existing ovens (Oven Nos. 2, 3, 4, 5, 6, 8, 9, and 1 0) bake 

only non-yeast doughs. (**Note: Oven No. 10 no longer exists) Mondelez installed a new oven 

(Oven No. 7), which is regulated by a new source permit and is not being addressed in this RACT 

determination. All the ovens are natural gas-fired. 

Doughs are conveyed along the length of the oven from front to the rear. The oven is enclosed 

except for an opening (about 5' x 0.4') at both the entrance and exit adequate for the passage of the 

dough on an automatic conveyor belt. 

4. Oil Treatment Facilities: Only oven lines 1, 2, and 4 have oil treatment facilities (one facility per 

line); the rest of the existing oven lines do not have any oil treatment facilities. The oil treatment 

facilities are spray chambers where vegetable oil is sprayed on the baked crackers for flavoring. 

These chambers are enclosed except for just adequate openings at both the entrance and exit for 

the passage of crackers on an automatic conveyor belt. The excess oil is collected at the bottom of 

the chamber, filtered, and returned to the system. The oil mist in the exhaust gas stream is removed 

by either a cyclone demister or a very small electrostatic precipitator (ESP) with a disposable filter. 

The exhaust is vented in to the building. 

The crackers exiting from the oil treatment facility are fed in to a continuous motion annealing 

conveyor for a slow and controlled temperature decrease; this process is called "post conditioning". 

C. UNCONTROLLED EMISSIONS 

1. Proof-room: A September 19-20, 1987 emission test on a proof-room at Mondelez's Houston, 

Texas plant, where the same premium crackers are produced, showed uncontrolled emissions of 

0.1 pounds of VOC per hour (a copy of the test report is available upon request). The proof-room 

operation at the Houston plant, considering dough batch size, proof time, and proof temperature, is 

similar to that at the Richmond plant. Based on the test at the Houston plant and 8760 hours per 

year of operation capacity, the uncontrolled VOC emissions from the proof-room at the Richmond 

plant are expected to be insignificant (0.4 tons per year (TPY)). 

2. Ovens: Table 1 presents a summary of the uncontrolled VOC emissions at this plant, as calculated 

for the initial RACT determination in 1991. The only significant source of VOC emissions is Oven 

No. 1. The annual plantwide uncontrolled VOC emissions were calculated to be 266 tons, of which 

261 tons are from Oven No.1. 

In the non-yeast dough process, the product is chemically leavened with baking powder. An 

acid/base reaction releases the carbon dioxide, causing the dough to rise without formation of any 

VOCs in significant amounts. Stack test data from Mondelez's similar bakery in Atlanta, Georgia 

was used to estimate emissions. The formulation and processing of non-yeast doughs at the Atlanta 

plant are similar to those at the Richmond plant. Based on the test at the Atlanta plant and the 

annual production capacities of ovens at the Richmond plant, the uncontrolled VOC emissions from 

baking of non-yeast doughs are calculated. As presented in Table 1, the uncontrolled VOC 

emissions are insignificant from baking of non-yeast doughs. 

In the yeast-dough process, VOC emissions are produced as a by-product of the leavening process. 

Fuel (natural gas) combustion emissions (NOx, CO, and SOx) are comparatively negligible. 

On December 8, 1988, emission tests for VOCs were conducted on Oven No. 1 at the Richmond 

plant. Based on this test and the maximum allowable production rate, the uncontrolled VOC 

emissions from oven No. 1 were calculated to be 261 TPY. 
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3. Oil Treatment Facilities: The oil mist emissions are currently controlled by either a demister 

cyclone or a very small ESP with a disposable filter. The exhaust is discharged in to the building. 

According to an August 21, 1990 policy memo "Interpretation of VOC Definition as Applied to 

Vegetable Oil" from EPA's Office of Air Quality Planning and Standards, vegetable oil emissions are 

not considered a VOC for the purpose of control programs for attaining the national ambient air 

quality standards for ozone since these emissions do not participate in the formation of ozone. 

D. CONTROL TECHOLOGY ASSESSMENT 

The VOC control technology assessment for this plant is described below. 

1. Proof-room: The uncontrolled VOC emissions from the proof-room are insignificant (0.4 TPY) and 

therefore, the RACT for the proof-room is determined to be no control. 

2. Ovens: The uncontrolled VOC emissions from Oven Nos. 2, 3, 4, 5, 6, 8, 9, and 10 are insignificant 

and therefore the RACT for these ovens is determined to be no add-on control, but a limit on their 

process to baking of only non-yeast dough. 

The primary source of VOC emissions is Oven No. 1. This oven is enclosed except for enough 

openings (about 5' x 0.4') at each end to allow for passage of the feed conveyor belt. The actual 

volume of gases generated during the baking process from combustion air and evaporation of water 

and VOC is only about 1, 900 scfm. The design and operation of this oven meet the criteria for a 

permanent total enclosure. 

As previously discussed, RACT for Oven No. 1 while baking sponge-dough was determined to be 

control of VOC emissions in part through the use of a catalytic incinerator with a destruction 

efficiency of 95%. Mondelez is proposing that the CTO be replaced with a RTO. While Mondelez 

is requesting a change in the type of control device, the emissions will not be affected as a result 

of the change because the destruction efficiency has remained the same. The RTO has a vendor 

guaranteed destruction efficiency of at least 95%. The RTO will be at least as efficient as the 

CTO that it is replacing. Because of these factors DEQ finds the request to be acceptable. 

Exhaust from Oven No. 1 will be ducted to the RTO. Natural gas will be used as an auxiliary fuel. 

3. Oil Treatment Facilities: EPA does not consider vegetable oil emissions as VOC for the purpose 

of control programs for attaining the national ambient air quality standards for ozone. Therefore, the 

RACT for these facilities is determined to be a limit on the type of oil used to only vegetable oils. 

E. AIR POLLUTION IMPACTS 

The use of the RTO is expected to reduce the plant VOC emissions by 95%. The combustion of 

auxiliary fuel (natural gas) in the RTO will generate an insignificant amount (0.6 TPY) of nitrogen 

oxides (NOx). The overall impact on air quality is expected to be beneficial. 

F. COST IMPACTS 

Since emissions from the source will not be changing as a result of the control change, a cost impact 

analysis has not been conducted. 

G. OTHER IMPACTS 

No other impacts, such as secondary emissions, increased water pollution discharge, or additional 

solid waste generation, are expected from the operation of the RTO. 
H. CONCLUSION 

DEQ concludes the following: 

1. RACT for the proof-room is no control. 

Mondelez Global LLC - Richmond Bakery 

PRO 50703 

Statement of Basis 

Page 17 

2. RACT for Oven No. 1, when backing yeast-dough, is design and operation of the oven that meet the 

criteria for a permanent total enclosure and use of a RTO or equivalent control device with a 

destruction efficiency of at least 95 percent. 

3. RACT for Oven No. 1, when backing non-yeast dough, is no control. 

4. RACT for Oven Nos. 2, 3, 4, 5, 6, 8, 9, and 10 is no add-on control, but a limit on their process to 

baking of only non-yeast dough. 

5. RACT for oil treatment facilities is a limit on the type of oil used to vegetable oils. 

The recommended RACT for Mondelez satisfies the EPA definition of RACT as both a technically 

feasible and cost-effective control option for reducing VOC emissions from the subject source. The 

secondary environmental impacts are expected to be minimal. 

I. ENFORCEMENT 

Under the authority of 9 VAC 5-40-7390 and 9 VAC 5-80-800 C, the legally enforceable mechanism 

for implementing the RACT requirements has been determined by DEQ to be this state operating 

permit. 

J. DETERMINATION OF COMPLIANCE 

Compliance for Oven No. 1, when baking yeast-dough, will be determined as follows: 

1. A performance test conducted on June 25, 2013 demonstrated compliance with the destruction 

efficiency of the RTO. Continued compliance will be demonstrated by maintaining the control device 

minimum combustion zone temperature and residence time that were established during the initial 

performance test or most recently DEQ approved performance test. 

2. A performance test conducted on June 25, 2013 demonstrated compliance with the requirement that 

the oven operate as a PTE. 

K. MONITORING AND RECORDKEEPING 

When baking yeast-dough in Oven No. 1, Mondelez will be required to continuously measure and record 

the combustion zone temperature of the RTO. 

Mondelez will also be required to maintain records of a log of observations of the device on the RTO and 

the dates of the performance testing. 
TABLE 1 

Mondelez Global LLC - Richmond Bakery 

PRO 50703 

Statement of Basis 

Page 18 

UNCONTROLLED VOC EMISSIONS 

MONDELEZ GLOBAL LLC, RICHMOND, VIRGINIA 

Facility Dough Type Uncontrolled VOC 

(tons/yr) 

Oven No.1 Yeast-dough 261 2 

Oven No.2 Non-yeast dough 0.5b 

Oven No.3 Non-yeast dough 1b 

Oven No.4 Non-yeast dough 0.6b 

Oven No.5 Non-yeast dough 0.5b 

Oven No.6 Non-yeast dough 0.6b 

Oven No.8 Non-yeast dough 0.3b 

Oven No.9 Non-yeast dough 0.3b 

Oven No. 10 Non-yeast dough 0.3b 

Proof-room Yeast-dough & Non-yeast dough 0.4c 

Oil-treatment facilities Yeast-dough & Non-yeast dough od 

(3) 

Total: 266 

aCalculated based on a December 8, 1988 emissions test on Oven No. 1 and the maximum 

allowable production rate. 

bCalculated based on the annual production capacities and a December 17, 1985 emissions 

test on a non-yeast dough oven at Mondelez's Atlanta, Georgia plant. 

cCalculated based on 8760 hours per year of operation capacity and a September 19-20, 

1987 emissions test on a proof-room at Mondelez's Houston, Texas plant. 

dEPA does not consider vegetable oil emissions as VOC. 
ENCLOSURE 2

PUBLIC PARTICIPATION CERTIFICATION

AND COMPLIANCE WITH

STATE ADMINISTRATIVE PROCEDURES

As required by 40 CFR 51.102 and Section 2.1 of Appendix V of 40 CFR Part 51, the 

following information regarding public participation activities and compliance with state 

administrative procedures is provided.

PUBLIC PARTICIPATION ACTIVITIES

As required by 40 CFR 51.102(a), a hearing to accept public comment concerning a 

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

was held in the Conference Room, DEQ Piedmont Regional Office, 4949-A Cox Road, 

Glen Allen, Virginia, at 9:00 a.m on February 4, 2014.

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

hearing along with the location of the proposal for public inspection in Style Weekly on 

January 8, 2014. The attached copy of the notice provides the evidence required by 

Section 2.1(f) of Appendix V of 40 CFR Part 51. As required by 40 CFR 51.102(f) and 

Section 2.1(g) of Appendix V of 40 CFR Part 51, the hearing was held in accordance 

with the information found in the public notice, and according to the state's laws.

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

of the hearing. This notification follows the requirements of 40 CFR Part 51.102(d)(3), 

(4) and (5).

Information on the record of the hearing, along with any comments received and 

responses thereto, is found in Enclosure 3.

COMPLIANCE WITH STATE ADMINISTRATIVE PROCEDURES

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 February 11, 2014, 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.

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RACT\RICHMOND5\MDZ-SIP-2.DOC
STYLE WEE!<LY [CLASSIFIEDS] January B, 2014 ~ 

Public NoticeEnvironmental Pennit 

Notice of action: The Department 

of Environmental Quality (DEQ) is 

announcing an opportunity ti.w public 

comment on a proposed plan regarding 

air pollution emitted by a litcility in 

Henrico County, Virginia. The Comnwnwcalth intends to submit the plan 

ns a rcvi.sion to the Commomvcalth 

of Virginia State Inipkmcntation Plan 

(SIP) in accordance with the requirement> of§ IIO(a) of the lcdcral Clean 

Air Acl. The SIP is the plan tb·elopcii 

by th!.?' Commonwealth in order f<) fulfill 

. its responsibilit~cs under the Act to 

attain and maintain the ambient air quality standards promulgated by the U.S. 

Environmental Protection Agency (EPA) 

under the Act. 

PuqlOse of notice: DEQ is seeking 

- comments and announcing a public 

hearing on a proposed pt:rmit to tim it 

air pollution emitted by a facility in 

Hcnri_co County. Virginia 

Public comment period: Janumy 8 to 

February I 0, 2014. 

Public hearing: Con terence Room, 

DEQ Piedmont Regional O!Tice, 4949-A 

Cox Rd, Glen Allen VA, at 9:00a.m. 

on February 4, 2014. A question and 

answer period will be held one half 

hour prior to the beginning of the public 

hearing. 

Permit name: State Operating Permit 

issued by DEQ, under the authority of 

the State Air Pollution Control Board. 

Name, address and registration 

number: Mondelez Global LLC. 

Inc. (lt>rmcrly Krafi Foods Global, 

Inc., Richmond Bakery), 6002 South 

Laburnum Ave, Richmond, VA 23231, 

Registration No. 50703. 

Description of propos!ll: Th~ proposed 

revision consists of a determination of 

reasonably available control technology 

(RACT) !(Jr the control of emissions 

of volatik organic compLlunds ( VOC) 

to the atmosphere from the Mondelez 

Global bakery located in the Henrico 

County, Virginia portion of the Rich-. 

mond Ozone Maintenance Area. The 

RACT dctcnnination is being made 

pursuant to 9VAC5-40-7370 of state 

regulations. A state operating permit 

is being is.'>ucd as an administrative 

mechanism to enforce the RACT determination. The permit is being issu~d 

pursuant to Article 5 (9VAC5-R0-800 et 

seq.) of9VAC5-SO (Permit lor Stationary Sources) of state regulations and is 

federally enforceable upon issuance. 

A permit was issued to the facility by 

DEQ on September 19. 2007. which 

contained the RACT fi1r the control of 

VOC emissions and spccillcd certain 

operating conditions for the facility's 

Oven# l and catalytic oxidizer. ln n 

subsequent action, the facility requested 

changes to the permit. including changes 

needed to accommodate replacement 

of the catalytic oxidizer with a more 

dlicient regcncrutive thermal oxidizer. 

This change in the type of control device 

did not afl'ect VOC emissions. The 

revised permit was issued on December 

II, 2012, and submitted to EPA as a SIP 

revision on December 13. 2012. Since 

then, the permit has been updated to 

make it more streamlined by removiilg 

certain conditions (throughput and ~mission limits) and regulatory references (to 

malfunctions) that are not necessary to 

achieve the RACT requirements. These 

changes arc in the interest of providing 

clarity. and will not result in any change 

in opern.tions or emissions incrCasc. 

Federal information: This notice is being given to satisfy the public participation requirements of federal regulations 

(40 CFR 51.102). The proposal will l1c submitted ns a revision to the Commonwe,)lth of Virginia SIP under§ IIO(a) of 

the ICdcral Clean Air Act in accordance 

with 40 CFR 51.104. 

How to comment: DEQ accepts written 

comments by email, fttx and postal 

mail. In order to be considered. written 

comments must include the full name, 

address and telephone number of the 

person commenting and be received by 

DEQ by the last day of the comment 

period. Both oral and written comments 

arc accepted at the public hearing. DEQ 

prefers that comments be provided 

in writing, along with any supporting 

documents or exhibits. A!! inlbnnation 

receivl'd is part of th.: publie record. 

-i{t review proposal: The proposal and 

any supporting documents are available 

on the DEQ Air Public Notices t<1r 

Plans web site: lntp://\VWW.dcq.statc. 

va. us/ Programs/ Air/Public Notices/airp!ansnndprograms.aspx. Th~ documc.:nts 

may also be obtained by contacting 

the DEQ representative named below. 

The public may reviC\\.' the documents 

between 8:30am and 4:30pm of each 

business day until th.e close of the 

public comment period at the f{Jliowing 

DEQ locations: I) Main Street Office, 

Sth Floor, 629 E. Main St, Richmond 

VA, 804-698-4070, and2) Piedmont 

Regional Office, 4949-A Cox Rd, Glen 

Allen VA, 804-527-5020. 

Contact for public comments. 

document requests and additional 

information: Jennifer Hoeffner, Environmental Engineer, DEQ Piedmont 

Regional Office, 4949-A Cox Rd. Glen 

Allen VA (phone 804-527-5123, 

fax 804-527-5106, emailjennifer.hoeffner@dcq.virginia.gov). 
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. 

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RACT\RICHMOND5\MONDELEZ\MDZ-SIP-3.DOC