Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

DATE: 

SUBECT:

February 26, 2014

Technical Support Document (TSD)—Virginia; 

Control of Volatile Organic Compound (VOCs) 

Emissions from the Mondelēz Global LLC, Inc.—

Richmond Bakery located in Henrico County, Virginia

 /s/

FROM: Irene Shandruk, Physical Scientist

Office of Air Program Planning (3AP30)

TO: Virginia; Docket No. EPA-R03-OAR-2014-0179

 /s/

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning (3AP30)

A. BACKGROUND

The Federal Clean Air Act requires that Virginia adopt and enforce a plan, known as the State 

Implementation Plan (SIP), to attain and maintain the National Ambient Air Quality Standards (NAAQS) 

throughout the Commonwealth. In 1985, a plan to attain and maintain the 1-hour ozone air quality 

standard in the Richmond Nonattainment Area was adopted. The 1985 plan provided that the State Air

Pollution Control Board must, on case-by-case basis, determine whether there is a reasonably available 

control technology (RACT) to reduce volatile organic compound (VOC) emissions from major sources 

for which the Environmental Protection Agency (EPA) has not issued a control technology guideline 

(CTG).

Under the 1-hour ozone standard requirements established by the Clean Air Act (CAA) Amendments 

of 1990, the Richmond area was designated as a moderate nonattainment area. The area’s air quality 

improved and a redesignation request and maintenance plan were sent to EPA and approved on 

November 17, 1997 (62 FR 61237). On July 18, 1997, EPA promulgated the 1997 8-hour NAAQS for 

ozone. On September 22, 2004, under the 1997 8-hour ozone standard, the Richmond area was 

classified as a marginal nonattainment area. On September 20, 2006, the Virginia Department of 

Environmental Quality (VADEQ) formally submitted a request to redesignate the Richmond area from 

nonattainment to attainment of the 8-hour NAAQS for ozone. On September 25, 2006, the VADEQ

submitted a maintenance plan for the Richmond area as a SIP revision to ensure continued attainment. 

The redesignation request and maintenance plan were approved on June 1, 2007 (72 FR 30485).
Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

Section 107(d)(3)(E) of the CAA stipulates that for an area to be redesignated, EPA must approve a 

maintenance plan that meets the requirements of Section 175A. All applicable nonattainment area 

requirements remain in place. The maintenance plan constitutes a SIP revision, and must provide for 

maintenance of the relevant NAAQS in the area for at least 10 years after redesignation. Virginia 

developed a maintenance plan that meets all EPA requirements and demonstrates that, because of 

permanent and enforceable measures, emissions will remain within the regional emissions budget 

while allowing for growth in population and vehicle miles traveled. The plan includes a demonstration 

that emissions will remain within the 2005 levels for a 10-year period by keeping in place key elements 

of the current Federal and state regulatory programs, including case-by-case RACT requirements for 

the area.

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

control technology that is reasonably available with the consideration of technological and economic 

feasibility. When the Richmond area was originally designated as an ozone nonattainment area under 

the 1-hour ozone standard, it was classified as “moderate” and thereby had to meet the non-CTG 

RACT requirements of §182. As part of the 1-hour ozone standard attainment plan, one of the sources 

located in the area identified as being subject to non-CTG RACT was Nabisco Brands (then Kraft 

Global Foods Inc. and currently Mondelēz Global LLC, Inc. Mondelēz cookies, crackers, and pretzels 

are produced at this plant using two different dough processes: yeast dough and non-yeast dough. In the 

yeast dough process, dough is formulated by yeast leavening; while in the non-yeast dough process, 

dough is leavened chemically in the absence of yeast. 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. On December 11, 2012, Mondelēz was 

granted a new permit to reflect a number of modifications to its process that necessitated revisions to its 

RACT permit, and was submitted to EPA as a SIP revision, dated December 13, 2012. Since then, the 

permit has been 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. Therefore, changes to the facility’s RACT permit necessitate a change to the SIP. These 

updates were submitted to EPA as a SIP revision, dated February 14, 2014 and received by EPA on 

February 18, 2014. These changes are in the interest of providing clarity, and will not result in any 

change in operations or emissions increases. Additionally, the December 13, 2012 submittal is being 

withdrawn by the Commonwealth.

B. EPA REQUIREMENTS

When the Richmond area was originally designated as an ozone nonattainment area under the 1-

hour ozone standard, it was classified as moderate and thereby had to meet the non-CTG RACT 

requirements of §182. Under the 1997 8-hour ozone standard the Richmond nonattainment area 

was designated as marginal. Under Section 182(b) of the CAA, stationary sources in moderate 

nonattainment areas must comply with the requirements for sources in marginal nonattainment 

areas. The additional, more comprehensive control measures in §182(b)(2)(B) require that existing 

stationary sources emitting VOC for which a CTG existed prior to adoption of the 1990 
Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

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 criteria pollutant.

C. EVALUATION OF STATE SUBMITTAL

In 2012, Mondelēz (formerly Kraft Foods Global, Inc.) made a number of modifications to its process 

that necessitated revisions to its RACT permit, and then additional updates were made to the permit in 

2013. Therefore, a SIP revision request concerning this RACT permit was submitted to EPA on 

February 14, 2014. Pursuant to the requirements of Section 110 of the CAA, Virginia is requesting 

approval of a SIP revision, which was approved by the Commonwealth and became effective on 

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 revision consists of a Federally enforceable state operating permit (which was drafted in 

compliance with the non-CTG RACT requirements of Article 5 of 9VAC5-80 (Permit for Stationary 

Sources) of state regulations, containing terms and conditions for the control of emissions of VOCs 

from the Mondelēz Global LLC, Inc.—Richmond Bakery located in Henrico County, Virginia. The 

purpose of the submittal is to meet the requirements for RACT in order to implement the attainment 

and maintenance plans for the Richmond 8-hour ozone maintenance area.

The revised permit consists of 20 conditions and Appendix A. Changes were made throughout the 

permit reflecting the following notable changes: 

(1) name changing from Kraft Foods Global, Inc to Mondelēz Global LLC, Inc.; 

(2) all references to the catalytic thermal oxidizer (CTO), the catalyst, and language 

associated with the CTO and catalyst were removed from the conditions and replaced with 

regenerative thermal oxidizer (RTO); 

(3) all references to “sponge dough” were replaced with “yeast dough” in the permit 

conditions; 

(4) all references to “straight dough” were replaced with “non-yeast dough” in the permit 

conditions; and 

(5) propane was removed as a type of fuel to be utilized by the ovens. 

(6) the date of the permit to be superseded has been updated.

Other specific changes are described below:

1. PROCESS REQUIREMENTS – VOC Equipment List

Condition 1 contains a table that no longer allows propane to be used as a fuel option for 

Ovens 1 through 9. Natural gas is the only fuel options available for Ovens 1 through 9. The only 

other change under Heading 1, Condition 1 is that the references to sponge dough and straight 

dough were changed to yeast dough and non-yeast dough respectively. This change was also made 

throughout the permit. EPA agrees with these changes since they have no effect on the VOC 

emissions.
Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

2. PROCESS REQUIREMENTS – VOC Emission Controls

Condition 2 was changed by Mondelēz’s need to update the aging VOC emission control 

equipment for Oven 1 from a catalytic thermal oxidizer (CTO) to a regenerative thermal oxidizer 

(RTO) maintaining the same VOC emissions control efficiency of 95%. Conditions 3, 4, were

changed by no longer only referencing the specific type of VOC emission control equipment (now 

RTO) but also including equivalent VOC emissions control devices to comply with the RACT 

requirement for Oven 1 of this permit. This change was also made throughout the permit.

Condition 3 describes the criteria for the permanent total enclosure (PTE) for this revised 

permit. Previously the PTE provisions were found in the appendix. 

Additional changes to Condition 4 relating to the new type of VOC emission control 

equipment requirement also includes changes to the methods used to monitor compliance. 

Compliance is determined by requiring the VOC emissions control equipment to be equipped with a 

monitoring device that is maintained, calibrated and operated in accordance with approved 

procedures consistence with the manufactures written requirements or recommendations. EPA 

agrees with these changes since they have no effect on the VOC emissions.

3. PROCESS REQUIREMENTS – Operational Limitations

Condition 8 has been removed since the new VOC emission control equipment, RTO does 

not require the use of a fan with a specific set point to determine compliance with the control 

devices destruction efficiency of 95% as did the previous VOC emission control equipment, CTO. 

Condition 8 now requires the facility to determine compliance by maintaining the minimum 

combustion zone temperature and residence time of the control device established during a VADEQ 

approved performance test. 

Condition 9 was added and requires the facility to keep a log of the observations related to 

the monitoring device that is used to ensure good performance of the new VOC emissions control 

equipment. Condition 10 has been removed since the throughput limit of yeast dough products for 

Oven #1 is not needed for RACT. Condition 11 has been removed since the throughput option is 

not needed for RACT. Condition 12 has been removed since the emission limit is not needed for 

RACT. EPA agrees with these changes since they have no effect on the VOC emissions.

4. TESTING

Condition 12 has been removed and replaced with Condition 13. The previous testing 

provision was required annually and was specific to the previous VOC emissions control equipment,

CTO. The new conditions are related to the RTO and require the facility to provide emissions 

testing upon reasonable notice by the VADEQ and also provide access to sampling ports in a safe 

environment. Initially, Condition 14 (stack test condition) was added as well, which specified that 

US EPA Test Methods 25 and 204 are to be used when conducting the initial performance testing 

with the current VOC emissions control equipment to be completed within 180 days after the 

facilities start-up date. The facility is also required to submit the test protocol 30 days prior to 

testing and further requires the facility to submit a copy of the test report within 60 days after the 

test is completed. The requirements of Condition 14 have been completed. The stack test and the 
Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free.

Customer Service Hotline: 1-800-438-2474

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 determined. Therefore, Condition 

14 has been removed. EPA agrees with these changes since they have no effect on the VOC 

emissions.

5. RECORDS

Condition 15.a and b have been removed. Condition 15.a. was a recordkeeping condition 

that correlated with Condition 10, which has also been removed. Condition 15.b was removed since 

it has been determined that they are not needed for RACT. EPA agrees with these changes since 

they have no effect on the VOC emissions.

6. NOTIFICATIONS

Condition 16.a and b associated with the RTO have been 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. Condition 17, the 

production notification, has been removed because it correlated with the Condition 10, which has 

also been removed. Condition 19 (malfunction) has been removed. EPA agrees with these changes 

since they have no effect on the VOC emissions.

D. RECOMMENDATION

The Commonwealth of Virginia has met the requirements for submitting a RACT SIP 

revision. The revision will result in the Richmond 1997 8-hour ozone maintenance area being able 

to implement its attainment and maintenance plans. Therefore, EPA approval of this SIP revision is 

recommended.