Molly Joseph Ward Secretary ofNatural Resources 

# COMMONWEALTHofVIRGINIA
DEPARTMENTOFENVIRONMENTAL QUALITY

Street address: 

### 629 EastMain Street, Richmond, Virginia23219

Mailing address: 

### P

.O. Box 1105, Richmond, Virginia 23218 Fax (804) 698-4500 TDD (804) 698-4021 www

### .deq.virginia.gov



# F

EB 14

# 2014

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 RevisionforMondelez Global LLC, Inc. (formerly KraftFoods)
DearMs. Esher:
Pursuanttotherequirements of§ 110 ofthe CleanAirAct, we are officiaJly requesting approval ofa revisiontothe CommonwealthofVirginia State ImplementationPlan(SIP) approved onFebruary 11, 2014underthe authority of§ 10.1-1185 ofthe Code ofVirginiaand submittedinaccordancewiththerequirements of40 CFRPart 51 (Requirements for Preparation, Adoption, and Submittal ofImplementationPlans). Theplanrevisionis effectiveuponthe date ofapproval, February 11 , 2014

. The revisionconsists ofa federally enforceable state operatingpermitcontaining terms and conditions for the control ofemissions ofvolatile organic compounds (VOCs) from the Mondelez Global LLC, Inc. (formerlyKraftFoods Global, Inc.) locatedinHenrico County, Virginia. This submittal is for thepirrpose ofmeeting therequirements for Reasonably Available Control Technology (RACT)inorderto implementthe attainment andmaintenanceplans for the Richmond OzoneMaintenance Area. This revisionis intendedto replace a previous SIP revision forthis facility, whichwas submittedto EPAonDecember 13, 2012; withthis letterwerequest withdrawal ofthat submittal.

### Enclosed arethe following:
1. SIP revision, includingthe federally enforceable state operatingpermit.
2. Publicparticipationcertificationandcompliancewith state administrativeprocedures.
3. Summary ofpublic commentandresponses thereto.
4. An

### electronic copy (CD) ofthe complete submittal. This electronic copy is anexact duplicate ofthehardcopy. Ifyouhave any questions orneed 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\

DavidK. 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 proof

room, ovens, and oil treatment facilities. The facility underwent RACT analysis, and a federally

-enforceable state operating permit was issued to the facility, which became effective on April 24, 1991 . The permit was then submitted to EPA as a SIP revision, and approved into the Commonwealth’s SIP on March 6, 1992 (57 FR 8080)

. Because the Richmond area in which this facility is located has continuously been classified as either a nonattainment or a maintenance area, the RACT requirements remain in effect, 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 ofNatural 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) forVolatile 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 ofthe Regulations ofthe Board and (ii) 

### establishes control technology and other requirements forthe control ofvolatile organic compound (VOC) emissions from the Mondelez Global, LLC- Richmond Bakery in the Richmond, Virginia Ozone MaintenanceArea. These RACT requirements shall be the legal and regulatory basis for control ofVOC emissions from this facility. This permit shall be effective upon approval by the U. S. Environmental Protection Agency following the requirements of40 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 AirAct and the Commonwealth ofVirginia Regulations for the Control and Abatement ofAir 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 ofthis permit. Approved on February 11, 2014.


## ·K}IM**lvar~nter,** P.E. DeputyRegional 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 equipmentwhich are sources ofVOG emissions and implemented through the remaining conditions ofthis 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 ofOven #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 meetthe following criteria:

a. Any natural draft openings shall be at least4 equivalent opening diameters from each VOG emitting point; b. The total area ofall natural draft openings shall not exceed 5 percent ofthe surface area of the enclosure's four walls, floor and ceiling; c. The average facial velocity ofairthrough the natural draft openings shall be at least 200 feet per minute and the direction offlow shall be into the enclosure. d. All access doors and windows shall be closed during routine operation ofthe Oven #1. e. All ofthe 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 ofthe Board

- Mondelez Global LLC (Mondelez) shall comply with all applicable Regulations ofthe Board including the requirements for monitoring, notification, recordkeeping, reporting, maintenance, and malfunction. Mondelez agrees that this permit is not construed to mean that its operation is automatically in compliance with all aspects ofthe Regulations ofthe Board. Compliance with all air pollution regulations must be a continuing, full time effort. (9 VAC 5-80-850) 6. Oil Type- The type ofoil used in the oil treatmentfacilities 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 ofthe RTO. The permittee shall keep a log ofthe observations ofthe 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 ofobservations ofthe combustion temperature monitoring device on the RTO. b. Results ofall stack tests, visible emission evaluations and performance evaluations. The records required by this permit shall be maintained by Mondelez for a minimum ofthe most recent three year period and made available for review and inspection by representatives ofthe 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 ofthe 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 ofthe written notification shall be sent to: Associate Director Office ofAir 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 ofthe date and time for each period during which any monitoring system is inoperative (exceptfor calibration), the nature ofthe system problems, and the repairs or adjustments thatwere made. (9 VAC 5-80-850) GENERAL CONDITIONS

14. Relationshipto Other Permit Requirements- Except to the extent that conditions in this permit may be more stringent, this permit does not supersede or replace any othervalid permit, regulatory or statutory requirement. Furthermore, this approval to operate shall not relieve Mondelez ofthe 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 ofVirginia State Implementation Plan, the permit is enforceable by EPA and citizens underthe federal Clean AirAct. (9 VAC 5-80-800 C.2 and 9 VAC 5-80-820 F) 16. Permit Modification- The Board may revise (modify, rewrite, change oramend) or repeal this permit with the consent of Mondelez, for good cause shown by Mondelez , oron its own motion provided approval ofthe revision or repeal is accomplished in accordance with Regulations ofthe 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 of40 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 ofthe conditions ofthis permit shall constitute a violation ofa Permit ofthe Board. Failure to comply may result in a Notice ofViolation and civil penalty. Nothing herein shall waive the initiation ofappropriate enforcement actions orthe issuance oforders as appropriate by the Board as a result ofsuch violations. Nothing herein shall affect appropriate enforcement actions by any otherfederal, 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 underthe terms and conditions ofthis 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 ofthis 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 ofthis permit or the State Air Pollution Control Board Regulations; and d. To sample ortest at reasonable times. For purposes ofthis condition, the time for inspection shall be deemed reasonable during regular business hours orwhenever 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 ofOwnership

- In the case ofa 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 ofthe change ofownership within 30 days ofthe transfer. (9 VAC 5-80-940) 20. Permit Copy -The permittee shall keep a copy ofthis permit on the premises ofthe 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 RegionalI. 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 ofChanges 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 ofa permit on December 11, 2012 (2012 permit). This permit contained the RACT forthe control ofVOC 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 ofdough 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 affectwhat has been established as RACT. Change: Condition 1equipment 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 OvenMondeh§z Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 3 2. Replacement ofthe catalytic thermal oxidizer (CTO) with a regenerative thermal oxidizer (RTO)
Mondelez: Mondelez stated that the replacement ofthe CTO with the RTO will benefit the environment and it will be ofcommercial importance to Mondelez. Mondelez requested this change in part based on the current state ofthe CTO due to its age, despite proper maintenance including the replacement ofthe catalyst in 2011. The request is also based on the fact thatthe 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 ofVOC 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 ofthe change because the destruction efficiency ofthe 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 requestby Mondelez. Furtherdetails aboutthe 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 yeastdough 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 Orderas, dough formulated by yeast leavening. Because the name change has no affect on the RACT determination and the name change clarifies the type ofdough, 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 aboutthe condition deletion are described below in item 19.
4. Replace references to "straightdough" with non-yeastdough 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 Orderthat was written to establish RACT included a definition section. Straight dough was defined in the Consent Order as, dough leavened chemically in the absence ofyeast. Because the name change has no affect on the RACT determination and the name change clarifies the type ofdough, 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 offuel to be utilized by the ovens has no affect on the RACT determination therefore DEQ finds the change to be acceptable. 

### Change: Condition 1was 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 ofa control device that achieves a destruction efficiency ofat 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 ifthere were operational issues with it. Part ofthe initial RACT determination was the control ofVOC emissions through the use ofa catalytic incinerator having a destruction efficiency of 95%. The item ofsignificance in this determination is the extent that the emissions are controlled, 95%, not the type ofcontrol. Not listing the specific control is not a relaxation ofthe RACT since the requirementwill stipulate that the control device must have a destruction efficiency of95% therefore, the emissions released to ambient airwould remain the same. The requirements of9 VAC 5-40-7370 will be metwith the revised language ofthis Condition. References to the control device in Condition 2 ofthe permit thatwill be revised to listthe RTO as the control device but it will also include language that will allow the replacement ofthe 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 ofthe 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 of95%. A notification requirement regarding the replacement ofthe 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 ofOven #1. This was added because itwas part ofthe initial RACT determination. The condition was also updated to include that VOC emissions will be controlled by a permanenttotal enclosure (PTE). Further explanation ofthis 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 ofOven #1, a permanent total enclosure (PTE) and a Regenerative Thermal Oxidizer (RTO) or equivalent control device as approved by DEQ, having a destruction efficiency ofat 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 1while baking sponge-dough was initially determined to be control ofVOC emissions in part by a PTE. Condition 3 included this requirement in the permit. Condition 3 also required that the PTE meetthe criteria presented in Appendix A. Appendix A described the requirements oftest 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 ofa PTE as a method ofVOC 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 meetthe following criteria: a. Any natural draft openings shall be at least4 equivalent opening diameters from each VOC emitting point; b. The total area of all natural draft openings shall not exceed 5 percent ofthe surface area ofthe enclosure's four walls, floor and ceiling; c. The average facial velocity of airthrough the natural draft openings shall be at least 200 feet per minute and the direction offlow shall be into the enclosure. d. All access doors and windows shall be closed during routine operation ofthe Oven #1. e. All ofthe 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 ofany 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 ofthe temperature being measured in Celsius degrees or± 0.5°C, whichever is greater." DEQ: Monitoring the average temperature from a control device is not consistentwith 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 ofthe RTO than the language that it had proposed. Mondelez agreed to DEQs suggestion. Condition 4 has also been updated to be consistentwith the language regarding control devices described in Condition 2. Changethat 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

### Mondelez Global LLC- Richmond Bakery PRO 50703 Statement of Basis Page6 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 ofthe 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 ortheir RTOs. Additionally, flow is not a required monitoring condition in other Mondelt§z facilities or most other applications ofan 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 ofthe permit. No additional measures are required to demonstrate compliance with the control device destruction efficiency. The requirement ofthe exhaust gas flow rate from Oven #1 was also a method ofdetermining 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 ofthe 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 ofyeast 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 ofclarity, 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 thatthis requirement is not needed for RACT, and in the interest ofclarity, 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 ofclarity, 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 Mondelez Global LLC- Richmond Bakery PRO 50703 Statement of Basis Page 7

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 ofthe 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 ofany 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 itwas 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 10) 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 atthe 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 forVOC from a control device equivalent ofthe 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 laterthan 180 days after start-up ofthe 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 ofthe tests are to be arranged with the Director, Piedmont Region. The permittee shall submit a test protocol at least 30 days priorto testing. One copy ofthe 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 of2012 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 Mondelez Global LLC- Richmond Bakery PRO 50703 Statement of Basis Page 8

The stack test condition is being removed from the permit. The requirements ofthis 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.bwas reviewed and it has been determined that it is not needed for RACT, and in the interest ofclarity, are therefore removing it. Condition 15.d is being revised to require results oftests rather than dates oftests 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 chambertemperature, 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 ofyeast 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 ofthe 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 ofyeast dough, Oven #1 or control device fails or malfunctions and may cause excess emissions for more than 1 hour." Since the issuance ofthe 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 ofconstruction ofthe RTO, the actual start-up date for the RTO, and for the replacement ofthe 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 ofthe RTO commenced within 30 days aftersuch date. b. The actual start-up date ofthe RTO within 15Mondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 9 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 ofthe 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 ofthis condition have been completed. The actual date of construction for the RTO was December 20, 2012. The actual start-up date ofthe 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 ofthe 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 permitto ensure good performance ofthe RTO. A recordkeeping 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 ofthe RTO. The permittee shall keep a log ofthe observations ofthe combustionmonitoring device." Condition 11.a states the following: "Log ofobservations ofthe temperature monitoring device on the RTO." 

### Otherchanges madetothe permit:
The date ofthe permitto be superseded has been updated. 

### IV. Emission Unit(s)/Process Description(s) The conditions ofthe 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 Mondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 10

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 orother requirement necessary to implement the federal Clean AirAct or the Virginia Air Pollution Control Law. The intent ofthis SOP is a source specific State Implementation Plan (SIP) Revision to make the conditions ofthe 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. TitleV Review- 9 VAC 5 Chapter80, 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 Mondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 11

1. In the 1985 SIP revision and again by letterof May 10, 1989, DEQ made a commitmentto establish emission standards in accordance with EPA policy requiring RACT for all non-CTG major stationary sources ofVOC emissions in Richmond area in orderto diminish orabate causes ofair 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 ofVOC emissions in the Richmond area. 3. On December21, 1989 Mondelez metwith 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 ofyeast-dough in Oven Number 1were estimated to be 261 tons peryear. 6. Uncontrolled VOC emissions from the baking ofnon-yeast dough were estimated to be less than 1 ton peryear foreach oven.
7. Uncontrolled VOC emissions from the proof-room were estimated to be 0.3 ton peryear. 8. According to an August 21, 1990 policy memo "Interpretation ofVOC Definition as Applied to Vegetable Oil" from EPA's Office ofAir Quality Planning and Standards, vegetable oil emissions are not considered as VOC for the purpose ofcontrol 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 ofVOC emissions as described below:

a. The design and proper operation ofthe oven that meet criteria ofa PTE as detailed in condition 3.
b. The use ofa RTO orequivalent control device having a VOC destruction efficiency ofat 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 forthe proof-room is determined to be no control.
13. RACT for the oil treatment facilities is determined to be a limit on the type ofoil used to only vegetable oils.
14. Oven Number 7 is regulated by a newsource permit and, therefore, it is not subjectto this permit.

### XI. Public Participation Mondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 12

Notice ofthe 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 sentto 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 ofthe State Operating Permit. Attachment: Appendix A- Reasonably Available Control Technology DeterminationMondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 13



### APPENDIX A Commonwealth ofVirginia StateAir Pollution Control Board State Implementation Plan Revision for Richmond MaintenanceArea 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 ofthe ozone standard in the past. In 1985 a plan to attain and maintain the ozone air quality standard in the Richmond Ozone NonattainmentArea 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 meetthe ozone airquality standard by the end of 1987. Therefore, continuing efforts were needed to bring the Richmond area into attainment for ozone. The Federal Clean AirAct mandated that all such plans require the implementation ofall 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 ofwhich was to require emission controls for presently uncontrolled majorstationary sources. Thus, in orderto have a fully approvable plan, control methods forthis category ofsources must be analyzed and, iffound to be reasonable, implemented. The 1985 plan provided thatthe 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 peryear (TPY) potential] for which EPA had not issued Control Techniques Guidelines (non-CTG).
EPA defined RACT as the lowest emission limitthat a particular source is capable of meeting by the application ofcontrol 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 shortterm evaluation program to permit the application ofa 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 determinationswere prepared and submitted by the Department of Environmental Quality (DEQ) to EPA as part ofthe 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)Mondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 14

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 forthe control ofVOC 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 Mondelezwas initially determining RACT alternatives it considered seven different controls. Theywere catalytic incineration, thermal incineration, carbon adsorption, scrubbing, condensation, bio-filters and process modification. At the time a similar RACT study had been completed bythe Bay Area Air Quality Management District (BAAQMD) for control ofethanol 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. 1at Mondelez because the process and emissions were fundamentally similarfor bread baking ovens and Oven No. 1at Mondelez.
Mondelez had proposed to install a catalytic incineratorwith avendor guaranteed destruction efficiency ofat least 95% to be considered as RACT. This RACT proposal was approved and memorialized in a ConsentAgreement and Orderwhich was subsequently incorporated into the SIP.
Atthis 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 thatthe replacement ofthe 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 ofthe 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 ofthe 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 ofall of permits issued by DEQ as well as all Regulations ofthe 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 ofthe 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 ofyeast. The potential sources ofVOC emissions atthis 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) undertightly controlled temperature and humidity. The yeast-doughs are proofed for about24 hours, while the non-yeast doughs are proofed for about one hour.Mondelez Global LLC- Richmond Bakery PRO 50703 Statement of Basis Page 15
3. Ovens: The primary source ofVOC emissions from this source category is ovens that bake yeastdoughs. There are nine existing baking ovens atthis plant, ofwhich only one oven (Oven No. 1) bakes yeast-doughs. The rest ofthe eight existing ovens (Oven Nos. 2, 3, 4, 5, 6, 8, 9, and 10) 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 ofthe 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 ofthe 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 ofthe 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 forflavoring. These chambers are enclosed exceptforjust adequate openings at both the entrance and exitfor the passage ofcrackers 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 ora 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 ofVOC per hour (a copy ofthe test report is available upon request). The proof-room operation atthe Houston plant, considering dough batch size, prooftime, and prooftemperature, is similar to that at the Richmond plant. Based on the test atthe Houston plant and 8760 hours per year ofoperation capacity, the uncontrolled VOC emissions from the proof-room atthe Richmond plant are expected to be insignificant (0.4 tons peryear (TPY)).
2. Ovens: Table 1 presents a summary ofthe uncontrolled VOC emissions at this plant, as calculated forthe initial RACT determination in 1991. The only significant source ofVOC emissions is Oven No. 1. The annual plantwide uncontrolled VOC emissions were calculated to be 266 tons, ofwhich 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 ofany VOCs in significant amounts. Stacktest data from Mondelez's similar bakery in Atlanta, Georgia was used to estimate emissions. The formulation and processing ofnon-yeast doughs atthe Atlanta plant are similarto those atthe Richmond plant. Based on the test atthe Atlanta plant and the annual production capacities ofovens atthe Richmond plant, the uncontrolled VOC emissions from baking ofnon-yeast doughs are calculated. As presented in Table 1, the uncontrolled VOC emissions are insignificantfrom baking of non-yeast doughs.
In the yeast-dough process, VOC emissions are produced as a by-product ofthe leavening process. Fuel (natural gas) combustion emissions (NOx, CO, and SOx) are comparatively negligible. On December 8, 1988, emission tests forVOCswere 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. 1were calculated to be 261 TPY.Mondelez Global LLC- Richmond Bakery PRO 50703 Statement of Basis Page 16
3. Oil Treatment Facilities: The oil mist emissions are currently controlled by either a demister cyclone or avery small ESP with a disposable filter. The exhaust is discharged in to the building. According to an August 21, 1990 policy memo "Interpretation ofVOC Definition as Applied to Vegetable Oil" from EPA's Office ofAir Quality Planning and Standards, vegetable oil emissions are notconsidered a VOC forthe purpose ofcontrol programs for attaining the national ambient air quality standards for ozone since these emissions do not participate in the formation ofozone. D. CONTROL TECHOLOGY ASSESSMENT The VOC control technology assessmentfor 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 ofonly non-yeast dough. The primary source ofVOC emissions is Oven No. 1. This oven is enclosed exceptfor enough openings (about 5' x 0.4') at each end to allow for passage ofthe feed conveyor belt. The actual volume ofgases generated during the baking process from combustion air and evaporation ofwater and VOC is only about 1,900 scfm. The design and operation ofthis oven meet the criteria fora permanent total enclosure. As previously discussed, RACT for Oven No. 1while baking sponge-dough was determined to be control ofVOC emissions in part through the use ofa catalytic incineratorwith 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 ofcontrol device, the emissions will not be affected as a result ofthe change because the destruction efficiency has remained the same. The RTO has a vendor guaranteed destruction efficiency ofat least 95%. The RTO will be at least as efficient as the CTO that it is replacing. Because ofthese factors DEQ finds the request to be acceptable. Exhaustfrom Oven No. 1will be ducted to the RTO. Natural gas will be used as an auxiliary fuel.
3. Oil Treatment Facilities: EPA does not considervegetable oil emissions as VOC for the purpose ofcontrol 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 ofoil used to only vegetable oils.
E. AIR POLLUTION IMPACTS
The use ofthe RTO is expected to reduce the plantVOC 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 ofthe 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 ofthe RTO.

### H. CONCLUSION DEQ concludes the following:
1. RACT forthe 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 ofthe oven that meetthe criteria for a permanenttotal enclosure and use ofa RTO or equivalent control device with a destruction efficiency ofat 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 ofonly non-yeast dough.
5. RACT for oil treatment facilities is a limit on the type ofoil 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 of9 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 ofthe RTO. Continued compliance will be demonstrated by maintaining the control device minimum combustion zone temperature and residence time thatwere 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 ofthe RTO. Mondelez will also be required to maintain records ofa log ofobservations ofthe device on the RTO and the dates ofthe performance testing.TABLE 1 Mondelez Global LLC

- Richmond Bakery PRO 50703 Statement of Basis Page 18

UNCONTROLLEDVOC EMISSIONS MONDELEZ GLOBAL LLC, RICHMOND, VIRGINIA Facility Dough Type UncontrolledVOC (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-yeastdough 0.4c
Oil-treatment facilities Yeast-dough & Non-yeast dough od (3)
Total: 266

aCalculated based on a December8, 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 peryear ofoperation 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

.

TEMPLATES\SOURCE

-SPECIFIC\PLN02 RACT\RICHMOND5\MDZ

-SIP

-2.DOCSTYLE WEE!<LY [CLASSIFIEDS] January 

### B, 2014**~**

Public NoticeEnvironmental Pennit Notice ofaction: The Department ofEnvironmental 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 ofVirginia State Inipkmcntation Plan (SIP) in accordance with the requirement> of§ IIO(a) ofthe lcdcral Clean AirAcl. 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 airquality standards promulgated by the U.S. Environmental Protection Agency (EPA) under the Act. PuqlOse ofnotice: DEQ is seeking

- comments and announcing a public hearing on a proposed pt:rmit to timit air pollution emitted by a facility in Hcnri_co County. Virginia Public commentperiod: Janumy 8 to February I0, 2014. Public hearing: Conterence Room, DEQ Piedmont Regional O!Tice, 4949-A Cox Rd, GlenAllen VA, at 9:00a.m.
on February4, 2014. A question and
answer period will be held one half hourpriorto the beginning ofthe public hearing. Permit name: State Operating Permit issued by DEQ, under the authority of the StateAir 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 ofpropos!ll:**Th~** proposed revision consists ofa determination of reasonably available control technology (RACT) !(Jr the control ofemissions ofvolatik organic compLlunds (VOC) to the atmosphere from the Mondelez Global bakery located in the Henrico County, Virginia portion ofthe Rich-. mond Ozone MaintenanceArea. The RACTdctcnnination is being made pursuant to 9VAC5-40-7370 ofstate 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) ofstate regulations and is federally enforceable upon issuance. Apermit was issued to the facility by DEQ on September 19. 2007. which contained the RACT fi1r the control of VOC emissions and spccillcd certain operatingconditions 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 ofthe catalytic oxidizer with a more dlicient regcncrutive thermal oxidizer. This change in the type ofcontrol 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 streamlinedby removiilg certain conditions (throughput and**~mis** sion limits) and regulatory references (to malfunctions) that are not necessary to achieve the RACT requirements. These changes arc in the interest ofproviding clarity. and will not result in any change in opern.tions oremissions incrCasc. Federal information:This notice is being given to satisfy the public participation requirements offederal regulations (40 CFR 51.102). The proposal will

### l1c submitted ns a revision to the Commonwe,)lth ofVirginia SIPunder§ IIO(a) of the ICdcral Clean AirAct in accordance with 40 CFR 51.104. How to comment: DEQ accepts written comments by email, fttx and postal mail. In orderto be considered. written comments must include the full name, address and telephonenumberofthe person commenting and be received by DEQ by the last day ofthe 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 partofth.: publie record. -i{t review proposal: The proposal and any supporting documents are available
on the DEQAir Public Notices t<1r Plans web site: lntp://\VWW.dcq.statc. va.us/Programs/Air/PublicNotices/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 ofeach business day until th.e close ofthe 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 publiccomments. 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.

TEMPLATES\RACT\PLN03 RACT\RICHMOND5\MONDELEZ \MDZ

-SIP

-3.DOC