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- 2474 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

- 2029

DATE:

SUB ECT: February 26, 2014

Technical Support Document ( TSD )

— Virginia; Control of Volatile Organic Compound (VOCs ) Emissions from the Mondel ēz 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

- 20 1 4

- 0179

/ s/

THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning (3AP30)

A. BACKGROUND

The F ederal Clean Air Act requires that Virginia adopt and enforce a plan, known as the State Implementation Plan (SIP), to attain and m aintain the N ational A mbient A ir Q uality S tandards (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 a nd 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, u nder the 1997 8

- hour ozone standard, t he Richmond area was classified a s a marginal nonattainment area. On September 2 0 , 200 6

, the Virginia Department of Environmental Quality (VADEQ) formally submitted a request to redesignate the Richmond a rea from nonattainment to attainment of the 8

- hour NAAQS for o zone

. O n September 25, 2006

, the VADEQ submitted a maintenance plan for the Richmond a rea as a SIP revision to ensure continued attainment. The redesignation request and maintenance plan were approved on June 1, 2007 (72 F R 30485 ).Printed on 100% recycled/recyclable paper with 100% post

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- 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, emiss ions 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 elem ents of the cur rent F ederal 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

- CT G RACT requirements of § 1 82. 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 (th e n Kraft Global Foods Inc. and currently Mondelēz Global LLC, Inc. Mondelēz c ookies, 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 l eavened 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 F ederally

- enforceable S tate operating permit was issued to the facilit y, 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 refle ct a number of modifications to its process that necessitat ed 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. Th ese 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 are a 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

w as designated as marginal. Under S ection 182(b) of the CA A, 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 1990Printed on 100% recycled/recyclable paper with 100% post

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- 2474 Amendments also use RACT. Section 1 82(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 20 12

, Mondelēz (former ly Kraft Foods Glo bal, Inc. ) made a number of modifications to its process that necessitat ed 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 Feb ruary 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, 201 4 under the authority of § 10.1

- 1185 of the Code of V irginia, 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 F ederally enforceable state operating permit (which was drafted in

com pliance with the non

- CTG RACT requirements of Article 5 of 9VAC 5

- 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

.

Th e revised permit consists of 2 0 c onditions and Appendix A

. Changes were made throughout the permit reflecting the following notable changes :

(1) name chang ing from Kraft Food s Global

, Inc to Mondelēz Global LLC, Inc. ; (2) all references to the catalyt ic thermal oxidizer (CTO), the catalyst, and language associated with the CTO and catalyst were removed from the conditions and replaced with

rege nerative 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 up dated.

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 f or 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

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- 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 (CT O) to a regenerative thermal oxidizer (RTO) maintaining the same VOC emissions control efficiency of 9 5%

. Conditions 3 , 4, were changed by no longer only referencing the specific type of VOC emission control equipment (now RTO) but also including equivale nt 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. Previous ly 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 requir ing 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 th ese 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 deter mine 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 reside nce 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 an nually 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 specifie d 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 thePrinted on 100% recycled/recyclable paper with 100% post

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- 2474 test associated with the PTE were conducted on June 25, 2013. The test data was submitted on August 23, 2013. The test data w as reviewed and compliance was determined. T herefore, 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 con dition 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 1 0, which has also been removed. Condition 19 (malfunction) has been removed

. EPA agrees with these changes since they have no effect on the VOC e missions.

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.