Douglas W. Domenech Secretary of Natural Resources 

# COMMONWEALTH of VIRGINIA

DEPARTMENT OF ENVIRONMENTAL QUALITY

Street address: 629 East Main Street, Ric hmo nd

, Vir ginia 23219

Mailing address: P .O. Box 1105, R ichmond, V irginia 232 18

TDD ( 804 ) 698-4021 www.deq.virginia.gov



## DEC 21 ZU1Z
Ms. Diana Esher, Director
Air Protection Division 

### (3APOO)
U.S. Environmental Protection Agency, Region III
1650 Arch Street Philadelphia, Pennsylvania 19103-2029 David K. Paylor

Director

(804) 698-4020
1-800-592-5482

Reference: SIP Revision for GP Big Island, LLC

Dear Ms. Esher:

Pursuant to the requirements of Section 11 0 of the Clean Air Act, we are officially requesting approval of a revision to the Commonwealth of Virginia State Implementation Plan (SlP) approved on October 5, 2012 under the authority of§ 10.1-1185 of the Code of Virginia
and submitted in accordance with the requirements of 40 CFR Part 51 (Requirements for Preparation, Adoption, and Submittal of Implementation Plans). The plan revision is effective

upon the date of this letter.

The revision consists of a revision to the state operating permit for the control of visibility-impairing emissions from GP Big Island, LLC, located in Bedford County, Virginia through the application of Best Available Retrofit Technology (BART). The department and the

company entered into a mutual determination of permanent shutdown of an individual unit consisting of the Number 4 Power Boiler, in accordance with 9V ACS-20-220, shutdown of a stationary source. The original state operating permit was then revised appropriately in order to reflect the unit shutdown. This permit action is for the purpose of the shutdown agreement only;
there was no BART determination, and the shutdown does not result in any emissions increase.Enclosed are the following:

1. SIP revision, including the fo1lowing:

A. Federally enforceable state operating permit.

B. Shutdown agreement.

C. Original permit.

2. Public participation certification.

3. Public participation record, including summary of comment and responses.

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

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

DKP\kgs

TEMPLA TES\SOURCE-SPECIFIC\PLNOO SRCESPEC\G-P BIG ISLAND 2\GPBI2-SIP.DOC

Enclosures 

# \ly. nO

)dil/J 

# J:f!ZA

David K. Paylor I •7
I

### ENCLOSURE 1

COMMONWEALTH OF VIRGINIA STATE IMPLEMENTATION PLAN REVISION FOR

UNIT SHUTDOWN AGR E EMENT AND REVISION TO THE STATE OPERATING PERMIT FOR G P BIG ISLAND , LLC

Section 110 of the federal Clean Air Act prescribes the requirements for the contents, adoption and submittal of the state implementation plan (SIP)

. Section 110 (a)(2)(D)(i)(II) requires that the plan contain adequate provisions prohibiting emissions in amounts which will interfere with measures required to be included in the plan to prevent significan t deterioration of air quality or to protect visibility.

Part C (Prevention of Significant Deterioration of Air Quality) of § 160 establishes the purposes of the part as follows:

(1) to protect public health and welfare from any actual or potential adv erse effect which in the Administrator's judgment may reasonably be anticipated to occur from air pollution or from exposures to pollutants in other media, which pollutants originate as emissions to the ambient air, notwithstanding attainment and maintenan ce of all national ambient air quality standards;

(2) to preserve, protect and enhance the air quality in national parks, national wilderness areas, national monuments, national seashores, and other areas of special national or regional natural,

recreat ional, scenic or historical value;

(3) to insure that economic growth will occur in a manner consistent with the preservation of existing clean air resources;

(4) to assure that emissions from any source in any state will not interfere with any porti on of the applicable implementation plan to prevent significant deterioration of air quality for any other state;
and

(5) to assure that any decision to permit increased air pollution in any area to which this section applies is made only after careful evaluation of all the consequences of such a decision and after adequate procedural opportunities for informed public participation in the decision making process.



### Section 165 addresses the preconstruction requirements for major sources to be built in

are as classified as PSD areas (f ederal c lass I areas). Section 165 (b)(2) addresses the responsibility of the federal land manager that has authority over federal class I areas:

The Federal Land Manager and the Federal official charged with direct responsib ility for management of such lands shall have an affirmative responsibility to protect the air quality related values (including visibility) of any such lands within a class I area and to consider, in consultation with the Administrator, whether a proposed major emitting facility will have an adverse impact on such
values.

. . . In cases where the Federal Land Manager demonstrates to the satisfaction of the state that the emissions from such facility will have an adverse impact on the air quality related va lues (including visibility)

. . . a permit shall not be issued.

### Section 169(A) addresses visibility protection for federal class I areas:

Congress hereby declares as a national goal the prevention of any future, and the remedying of any existing, impair ment of visibility in mandatory class I Federal areas which impairment results from manmade air pollution.



### This section also provides timeframes by which the Secretary of the Interior and the Administrator will interact to assess visibility, develop feder al regulations including specific source exemptions and public participation and the promulgation of those regulations.

Section 169(B) addresses the need for studies and assessment of current sources of visibility, impacts of other provisions, establishme nt of visibility transport regions and commissions, duties of the Administrator and the establishment of the Grand Canyon Visibility Transport Commission.

40 CFR 51.166, SIPs for new source review and source modifications, requires that the plans (in acco rdance with the policy of § 101(b)(1) and the purpose of § 160 contain emission limitations and such other measures as may be necessary to prevent significant deterioration of air quality.

V isibility is specifically addressed in 40 CFR 51.166 (o)

, a ddition al impact analysis:

(1) The owner or operator shall provide an analysis of the impairment to visibility, soils, and vegetation that would occur as a result of the source or modification and general commercial, residential, industrial, and other growth a ssociated with the source or modification....



### 40 CFR 51.166 (p) addresses sources affecting f ederal c lass I areas

- additional requirements.

(p)(2) The Federal Land Manager and the Federal official charged with direct responsibility for management of Clas s I lands have an affirmative responsibility to protect the air quality related values (including visibility) of any such lands and to consider, in consultation with the with the Administrator, whether a proposed source or modification would have an advers e impact on such
values.



### On July 1, 1999, the U.S. Environmental Protection Agency ( EPA ) published a final rule to address regional haze (64 FR 35714). The regional haze rule requires states to submit SIPs to address regional haze visibility impairment i n federally protected parks and wilderness areas, which are known as " mandatory Class I federal areas " or " Class I

areas. " The 1999 rule was issued to fulfill the requirements of §§ 169A and 169B. In this rule, EPA included a requirement for BART for cer tain large stationary sources that were put in place between 1962 and 1977. The regulatory requirements for BART were codified at 40 CFR 51.308(e) and in definitions that appear in 40 CFR 51.301.

Sections 169A(b)(2)(A) and 169A(g)(7) use the term " major stationary source " to describe those sources that are the focus of the BART requirement. To avoid confusion with other requirements which also use the term " major stationary source, "

### the regional haze rule uses the term " BART

- eligible source. " BART

- eligi ble sources (i) have the potential to emit 250 tons or more of a visibility

- impairing air pollutant, (ii) were in place between August 7, 1962 and August 7, 1977, and (iii) have operations that fall within one or more of 26 listed source categories. BART is required for any BART

eligible s ource which a state determines " emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in any such area." Accordingly, for stationary sources meeting these crit eria, states must address the BART requirement when developing regional haze SIPs.

Section 169A(g)(7) requires that states consider the following factors in making BART determinations: (i) the costs of compliance, (ii) the energy and nonair quality enviro nmental impacts of compliance, (iii) any existing pollution control technology in use at the source, (iv) the remaining useful life of the source, and (v) the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology. These statutory factors for BART were codified at 40 CFR 51.308(e)(1)(ii).

On July 6, 20 05 (70 FR 39103), EPA promulgated final regulations to address the court’s decisions (40 CFR 51.302 and 51.308), and to provide BART determination
g uidance (Appendix Y to 40 CFR Part 51). The purpose of the guidelines is to assist states as they identify which of their BART

- eligible sources should undergo a BART analysis, and select controls in light of the statutory factors (the BART determination).

GP Big Island, LLC (formerly Georgia

- Pacific Big Island ) , located in Bedford County, Virginia, w as identified as a source subject to the BART requirements

. A legally enforceable mechanism (federally enforceable state operating permit) was drafted to

ens ure compliance with the BART requirements. The permit is being issued pursuant
to Article 52 (9 VAC 5

- 40

- 7550 et seq.) of 9 VAC 5

- 40 (Existing Stationary Sources) and Article 5 (9 VAC 5

- 80

- 800 et seq.) of 9 VAC 5

- 80 (Permits for Stationary Sources) of sta te regulations

, and was federally enforceable upon issuance.

Subsequently, on January 5, 2012

, GP Big Island, LLC and the department joined a mutual determination of permanent shutdown of an individual unit consisting of the Number 4 Power Boiler

, in acco rdance with 9VAC5

- 20

- 220, s hutdown of a stationary

source

.

The original state operating permit also provides that:

The Board may revise (modify, rewrite, change or amend) or repeal this permit with the consent of GP Big Island, LLC , for good cause shown by GP Big Island, LLC , or on its own motion provided approval of the revision or repeal is accomplished in accordance with Regulations of the Board and the Administrative Process Act (§ 2.2

- 4000 et seq.). Such revision or repeal shall not be effective un til the revision or repeal is approved by the U. S. Environmental Protection Agency following the requirements of 40 CFR Part 51 (Requirements for Preparation, Adoption, and Submittal of Implementation Plans).



### The state operating permit was revised in ord er to reflect the unit shutdown , and the

### department regional office approved and issued the permit on October 5, 2012

. The permit was issued pursuant to Article 52 (9VAC5

- 40

- 7550 et seq.) of 9VAC5

- 40 (Existing Stationary Sources) and Article 5 (9VAC5

- 80

- 8 00 et seq.) of 9VAC 5

- 80 (Permits for Stationary Sources) of state regulations and became federally enforceable upon issuance. Because the unit is permanently shut down and the state operating permit has been revised accordingly

, the department is request ing that EPA approve the revised permit as a SIP revision

.
As provided in 40 CFR 51.302(b)(2), the federal land manager (FLM) was given the opportunity to comment on this permit on August 7, 2012

. In an electronic mail dated August 30, 2012

, the FLM decl ined a 30

- day review period for the amended permit.

The revised state operating permit is provided in Attachment A, and t he shutdown agreement between GP Big Island, LLC and the department is provided in Attachment B

. T he original pe rmit is included as At tachment C

.

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### ATTACHMENT A

LEGALLY ENFORCEABLE MECHANISM (PERMIT) TO ENSURE COMPLIANCE WITH BART REQUIREMENTS FOR

GP Big Island, LLC
B edford County , Virginia

Registration No. 30389

Under the authority provided in 9VAC5

- 170

- 180 and Section I I of Agency Policy Statement No. 3

- 200 6 (dated October 20, 200 6 ) , the Director of the Blue Ridge Regional Office approved and issued the permit on October 5, 2012 . The permit was approved and issued following the procedural requiremen ts 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)

.

### ATTACHMENT B

LEGALLY ENFORCEABLE MECHANISM (MUTUAL DETERM INATION OF PERMANENT SHUTDOWN) TO ENABLE SHUTDOWN OF THE NUMBER 4 POWER BOILER FOR

GP Big Island, LLC
B edford County , Virginia

Registration No. 30389

Under the authority provided in 9VAC5

- 20

- 220, the Director of the Blue Ridge Regional Office signed a mutual determ ination of permanent shutdown permanent shutdown of an individual unit consisting of the Number 4 Power Boiler for GP Big Island, LLC on January 5, 2012 , to be effective that same day. The determination was issued following the procedural requirements of 9VA C5

- 20

- 220 of Part II of 9VAC5

- 20 (General Provisions).

### ATTACHMENT C

ORIGINAL LEGALLY ENFORCEABLE MECHANISM (PERMIT) TO ENSURE COMPLIANCE WITH BART REQUIREMENTS FOR

GP Big Island, LLC
B edford County , Virginia

Regist ration No. 30389

Under the authority provided in 9VAC5

- 170

- 180 and Section I I of Agency Policy Statement No. 3

- 200 6 (dated October 20, 200 6 ) , the Director of the Blue Ridge Regional Office approved and issued the permit on June 12, 2008

, 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)

.

Because a uni t covered by the original permit is permanently shut down, the department is requesting that EPA replace the original permit with the new permit reflecting the shutdown.

Only the original permit document is provided here for reference and comparison
purpo ses . The original engi neering analysis and federal land manager (FLM) correspondence that accompanied the original permit are extremely lengthy, and are available on request.

### 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 co mpliance with state administrative procedures is provided.

PUBLIC PARTICIPATION ACTIVITIES

As required by 40 CFR 51.102(a), a public comment period to provide the opportunity to submit written comments concerning a proposed revision to the Commonwealth o f Virginia State Implementation Plan was held from November 19 through December 19

, 201 2

.
As required by 40 CFR Part 51.102(a) and (d)(1) and (2), the public was given notice of the public comment period in the Virginia Register , along with the location o f the proposal for public inspection, on November 19 , 201 2 . The notice included procedures to afford the public the opportunity to request that a hearing be held pursuant to 40 CFR 51.102(a); no such request was received. The attached copies of the notice provides the evidence required by Section 2.1(f) of Appendix V of 40 CFR Part 51.

The Regional Administrator for the U.S. Environmental Protection Agency was notified of the public comment period. This notification follows the requirements of 40 CFR Part 51.102(d)(3). T he federal land managers (FLMs) were given the opportunity to comment on this permit on August 7, 2012

. The FLMs declined to comment on the permit, and n o meeting was requested

.
The complete record of the public comment period is located at the Air Division of the Department of Environmental Quality. The d epartment contact to access this information is the Director, Air Division . A summary of the public comment period is attached.

COMPLIANCE WITH STATE ADMINISTRATIVE PROCEDURES

As req uired by Section 2.1(b) of Appendix V of 40 CFR Part 51, the permit was issued by the Department of Environmental Quality on October 5, 2012 . The statement of authority and procedures followed for approval and issuance of the permit and the signature of t he 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 State Implementation Plan is included in Attachment A to Enclosure 1

.

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## General Notices/Errata

Volume 29, Issue 6 Virginia Register of Regulations November 19, 2012

1291 http://www.deq.virginia.gov/Programs/Water/WaterQualityIn formationTMDLs/TMDL/TMDLDevelopment/DraftTMDLR eports.aspx

. The public comment period for the IP will end on January 4, 2013. Written comments should include the name, address, and teleph one number of the person submitting the comments and should be sent to Nesha McRae, Department of Conservation and Recreation, P.O. Box 1, Verona, VA 24482, telephone (540) 332

- 9238, FAX (540) 248

- 3069, or email nesha.mcrae@dcr.virginia.gov.

Notice of Publ ic Meeting and Public Comment

The Department of Environmental Quality (DEQ) and the Department of Conservation and Recreation (DCR) seek written and oral comments from interested persons on the development of a total maximum daily load (TMDL) implementatio n plan for the Linville Creek watershed in Rockingham County and the Town of Broadway. Linville Creek was first listed as impaired on the Virginia's § 303(d) TMDL Priority List and Report due to violations of the state's water quality standard for bacteria and the general water quality standard for aquatic life (benthic impairment) in 1998.
The creek has remained on the § 303(d) list for these impairments since then. Both impairment designations on Linville Creek begin at the headwaters and extend 13.55
mil es to its confluence with the North Fork of the
Shenandoah River.

Section 303(d) of the Clean Water Act and § 62.1

- 44.19:7 C of the Code of Virginia require DEQ to develop TMDLs for pollutants responsible for each impaired water contained in Virginia's § 3 03(d) TMDL Priority List and Report. In addition, § 62.1

- 44.19:7 C of the Code of Virginia requires the development of an implementation plan (IP) for approved TMDLs. The IP should provide measurable goals and the date of expected achievement of water qual ity objectives. The IP
should also include the corrective actions needed and their associated costs, benefits, and environmental impacts. Bacteria and benthic TMDLs were completed by the DEQ for Linville Creek in March 2003 and were approved by the
Environ mental Protection Agency in September 2003. The TMDL report is available for review on the VADEQ website

at: http://www.deq.virginia.gov/portals/0/DEQ/Water/ TMDL/apptmdls/shenrvr/linville.pdf

. The first public meeting on the development of this TMDL Implementation Plan will be held on Tuesday, November 27, 2012, at 7 p.m. at the Linville Edom Ruritan Hall, 3752 Linville Edom Road, Linville, VA 22834.

The public comment period for the first public meeting will end on December 31, 2012. Written comments should include the name, address, and telephone number of the person submitting the comments and should be sent to Nesha McRae, Department of Conservatio n and Recreation, P.O. Box 1, Verona, VA 24482, telephone (540) 332

- 9238, FAX (540) 248

- 3069, or email nesha.mcrae@dcr.virginia.gov.

Environmental Permit

- Bedford County, Virginia

Purpose of notice: The Department of Environmental Quality (DEQ) is announc ing an opportunity for public comment on a permit to limit air pollution emitted by a facility in Bedford County, Virginia. The Commonwealth intends to submit the permit as a revision to its state implementation plan (SIP) in accordance with the requiremen ts of § 110(a) of the federal Clean Air Act. The SIP is the plan developed by the Commonwealth in order to fulfill its responsibilities under the
federal Clean Air Act to attain and maintain the ambient air quality standards promulgated by the U.S. Environ mental Protection Agency (EPA) under the Act. DEQ is seeking comment on the issue of whether the amended permit should
be submitted as a revision to the SIP.

Public comment period: November 19, 2012, through December 19, 2012.

State public hearing procedur e: Interested persons may request a public hearing. The request must be made in writing to the contact listed below and be received by DEQ by the last day of the comment period. In order to be considered, the request must include the full name, address and telephone number of the person requesting the hearing and of all people represented by the requester. The request must also include: (i) the reason why a public hearing is requested; (ii) a brief statement setting forth the factual nature and extent of in terest in the proposed permit, including how the operation of the facility affects the requester; and (iii) specific references to applicable terms and conditions of concern as well as suggested revisions. A public hearing may be held as required by § 10.1

- 1322.01 of the Code of Virginia if at least 25 requests are received in accordance with these procedures. Notice of the date, time, and location of any requested public hearing will be announced in a separate notice, and another
30

- day comment period will be conducted.

Federal public hearing procedure: Interested persons may request a public hearing. The request must be made in writing to the contact listed below and be received by DEQ by the last day of the comment period. In order to be considered, the

r equest must include the full name, address and telephone number of the person requesting the hearing and of all people represented by the requester. A public hearing will be held as required by 40 CFR 51.102(a) if a request is received in
accordance with t hese procedures. Notice of the date, time, and location of any requested public hearing will be announced in a separate notice and another 30

- day comment period will be conducted.

Permit name: State operating permit issued by DEQ, under the authority of th e State Air Pollution Control Board.

## General Notices/Errata

Volume 29, Issue 6 Virginia Register of Regulations November 19, 2012

1292 Name, address and registration number: GP Big Island, LLC, 9363 Lee Jackson Highway, Big Island, Virginia 24526, Registration No. 30389.

Description of proposal: Virginia's regional haze regulation is
found in Article 5 2 (9VAC5

- 40

- 7550 et seq.) of 9VAC5

- 40, Existing Stationary Sources. This regulation provides guidance for determining Best Available Retrofit Technology (BART) as required by 40 CFR 51.302, 40 CFR 51.308 and Appendix Y to 40 CFR Part 51. BART is required f or any BART

- eligible source which emits any air pollutant which may reasonably be anticipated to cause or contribute to visibility impairment in any federal Class I area. BART is an emission limitation based on the degree of reduction achievable through ap plication of the best system of continuous emission reduction for each visibility

- impairing pollutant emitted by an existing stationary facility established

on a case

- by

- case basis. GP Big Island, LLC is subject to these requirements, has undergone a BART analysis resulting in the application of BART controls, and has obtained a state operating permit containing BART controls which was submitted to EPA as a SIP revision on July 17, 2008. Subsequently, GP Big Island, LLC and the department joined
a mutual de termination of permanent shutdown of an individual unit consisting of the No. 4 Power Boiler.

The current proposed revision consists of (i) the mutual and final determination between the source and the department, signed on January 5, 2012, that the No. 4 Power Boiler is permanently shut down and (ii) the associated state operating permit revised and issued on October 5, 2012, as the administrative mechanism to ensure continuing compliance with BART requirements. The permit was issued pursuant to
Article 52 (9VAC5

- 40

- 7550 et seq.) of 9VAC5

- 40 (Existing Stationary Sources) and Article 5 (9VAC5

- 80

- 800 et seq.) of
9VAC5

- 80 (Permits for Stationary Sources) of state regulations. Because the permit has been issued, DEQ is accepting comment only on whether the amen ded permit
should be submitted as a revision to the SIP and not on the content of the permit.

Federal information: This notice is being given to satisfy the public participation requirements of federal regulations (40
CFR 51.102). The proposal will be subm itted as a revision to the Commonwealth of Virginia SIP under § 110(a) of the
federal Clean Air Act in accordance with 40 CFR 51.104.

How to comment: DEQ accepts written comments by email, fax, and postal mail. In order to be considered, written

comments m ust include the full name, address and telephone number of the person commenting and be received by DEQ by the last day of the comment period. All materials received are part of the public record.

To review proposal: The proposal and any supporting
documen ts are available on the DEQ Air Public Notices for
Plans website: http://www.deq.state.va.us/Programs/Air/Publi cNotices/airplansandprograms.aspx . The documents m ay also be obtained by contacting the DEQ representative named below. The public may review the documents between
8:30 a.m. and 4:30 p.m. of each business day until the close of the public comment period at the following DEQ locations:

1) Main Street Offi ce, 8th Floor, 629 East Main Street, Richmond, VA and

2) Blue Ridge Regional Office, 7705 Timberlake Road, Lynchburg VA

Contact for public comments, document requests and additional information: Jan Phillips, Administrative Supervisor, Department of Envir onmental Quality, Blue Ridge Regional Office, 7705 Timberlake Road, Lynchburg VA, telephone (434) 582

- 6218, FAX (434) 582

- 5125, email jan.phillips@deq.virginia.gov.

Environmental Permit

- Henrico County, Virginia

Notice of action: The Department of Environ mental Quality (DEQ) is announcing an opportunity for public comment on a proposed plan regarding air pollution emitted by a facility in Henrico County, Virginia. The Commonwealth intends to submit the plan as a revision to the Commonwealth of Virginia sta te implementation plan (SIP) in accordance with the requirements of § 110(a) of the federal Clean Air Act. The SIP is the plan developed by the Commonwealth in order to fulfill its responsibilities under the Act to attain and maintain the ambient air quali ty standards promulgated by the U.S. Environmental Protection Agency (EPA) under the Act.

Purpose of notice: DEQ is seeking comments and announcing a public hearing on a proposed permit to limit air pollution emitted by a facility in Henrico County, Virgin ia.

Public comment period: October 31, 2012, to November 30,
2012.

Public hearing: Conference Room, DEQ Piedmont Regional Office, 4949

- A Cox Road, Glen Allen, VA, at 9 a.m. on November 30, 2012. A question and answer period will be held one half hour prior to the beginning of the public hearing.

Permit name: State Operating Permit issued by DEQ, under the authority of the State Air Pollution Control Board.

Name, address and registration number: Kraft Foods Global, Inc., Richmond Bakery, 6002 South Laburnum Avenue, Richmond, VA 23231, Registration No. 50703.

Description of proposal: The proposed revision consists of a determination of reasonably available control technology (RACT) for the control of emissions of volatile organic compounds (VOC) to the atmosph ere from the Kraft Foods bakery located in the Henrico County, Virginia portion of the
Richmond Ozone Maintenance Area. The RACT determination is being made pursuant to 9VAC5

- 40

- 7370 of state regulations. A state operating permit is being issued as
an admi nistrative mechanism to enforce the RACT

### 1 ENCLOSURE 3

PUBLIC PARTICIPATION RECORD

As required by 40 CFR 51.102(e), the complete record of the public participation period is located at the Air Division of the Department of Environmental Quality. The d epartment contact to access this informat ion is the Director, Air Division

.

The state did not receive comment on this particular revision.

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