UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: July 19, 2016

SUBJECT: Technical Support Document for Virginia’s Approval and Promulgation of Air 

Quality Implementation Plans for Control of Emissions of Volatile Organic 

Compounds from the Reynolds Consumer Products LLC – Bellwood Printing 

Plant

FROM: Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND: 

On October 26, 2015, the Environmental Protection Agency (EPA) received a revision to the 

Commonwealth of Virginia’s State Implementation Plan (SIP) submitted by Virginia Department 

of Environmental Quality (VADEQ). Under the authority of §10.1-1308 of the Code of Virginia 

and pursuant to the requirements of section 110 of the Clean Air Act (CAA), VADEQ submitted 

a SIP revision that requests inclusion of a state operating permit containing conditions and terms 

for the control of emissions of volatile organic compounds (VOCs) for the Bellwood Printing 

Plant, owned and operated by Reynolds Consumer Product LLC (Reynolds), located in 

Chesterfield, Virginia. The SIP revision would remove a consent agreement and order (consent 

order) previously included in the Virginia SIP to address reasonably available control technology 

(RACT) requirements for VOC control at Reynolds’ plant and include Reynolds’ state operating 

permit in the SIP to continue to address RACT requirements for Reynolds. The Reynolds’ 

permit also contains administrative and technical changes related to VOCs compared to the 

Reynolds’ consent order; however, the changes will have no effect on facility operation or air 

quality. 

The CAA requires that the Commonwealth of Virginia adopt and enforce a SIP, to attain and 

maintain the national ambient air quality standards (NAAQS). The SIP provides that Virginia

must, on case-by-case basis, determine whether there is RACT available to reduce volatile 

organic compounds (VOCs) from major sources of VOCs for which EPA has not issued a control 

technology guideline (CTG).

Under the 1-hour ozone NAAQS, the Richmond Area was designated as a moderate 
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nonattainment area. A redesignation request and maintenance plan was sent to EPA and 

approved on November 17, 1997. 62 FR 61237. On July 18, 1997, EPA promulgated an 8-hour 

ozone NAAQS. On September 22, 2004, the Richmond Area was classified as a marginal 

nonattainment area. On September 20, 2006, VADEQ submitted a request to redesignate the 

Richmond Area from nonattainment to attainment of the 8-hour ozone NAAQS. On September 

25, 2006, 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 by 

EPA on June 1, 2007.72 FR 30485. The maintenance plan included case-by-case RACT 

requirements for the Richmond Area which were approved by EPA for the Virginia SIP, 

including RACT for the Reynolds’ plant. 

EPA defines RACT as “the lowest emission limitation that a particular source is capable of 

meeting by the application of control technology that is reasonably available considering 

technological and economic feasibility.” 44 FR 53761 (September 17, 1979). When the 

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

ozone NAAQS, it was classified as “moderate” and thereby had to meet the non-control 

technique guidelines (non-CTGs) RACT requirements under section 182(b)(2) of the CAA. As 

part of the original attainment plan, Reynolds’ plant was identified by Virginia as being subject 

to non-CTG RACT. The facility underwent RACT analysis, and Virginia and Reynolds entered 

a consent order on October 30, 1986 to establish VOC RACT for the facility. Virginia submitted 

the consent order to EPA as a SIP revision to address RACT requirements in sections 172 and 

182(b)(2) of the CAA, and EPA approved the SIP revision as addressing RACT for Reynolds and

thus the consent order was incorporated into the Virginia SIP on June 6, 1996. 61 FR 29963. 

Virginia has since decided to include the VOC RACT provisions for Reynolds in a state 

operating permit and to remove the consent order from the SIP and to replace the consent order 

with the operating permit for the SIP. Virginia stated that the Reynolds’ permit was completed to 

ensure compliance with the non-CTG RACT requirements in Article 51 of 9VAC5-40 (Existing 

Stationary Sources). According to Virginia, the state operating permit for Reynolds contains 

essentially the same VOC requirements as the consent order and continues to address VOC 

RACT for Reynolds for the Virginia SIP to meet CAA requirements in sections 172 and 182 of 

the CAA. 

B. STATE SUBMITTAL:

According to Virginia, the Reynolds’ state operating permit contains the equivalent VOC RACT 

provisions which EPA previously approved for Reynolds (see 61 FR 29963) in the Virginia and 

Reynolds consent order with the minor exception of two typographical errors in the formula used 

to calculate the estimated percent reduction in VOC emissions at Reynolds’ plant. The formula 

with the typographical errors was approved into the Commonwealth’s SIP on June 6, 1996 (61 

FR 29963). The revised formula for the state operating permit merely corrects a typographical 

mistake made within the consent order but does not alter how VOCs are or were calculated nor 

affect VOC emissions from the plant. The current definitions in the SIP for X14 and X15 are as 
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follows: X14 = total actual solvent usage for time period =

X14+X5+X6+X7+X8+X9+X10+X11+X12+X13, and X15 = Total estimated solvents the plant 

is capable of using if water based (WB) materials were not used = X14+X0+X1+X2+X3-X14-

X5-X6-X7. The revised definitions for X14 and X15 are as follows: X14 = total actual solvent 

usage for time period = X4+X5+X6+X7+X8+X9+X10+X11+X12+X13, and X15 = total 

estimated solvents the plant is capable of using if WB materials were not used = 

X14+X0+X1+X2+X3-X4-X5-X6-X7. Virginia states that these minor changes (highlighted in 

bold) are administrative – correcting a prior inadvertent error in the formulas- and will have no 

impact on facility operation or air quality or on VOC emissions nor RACT requirements. 

Reynolds had been calculating its solvent usage correctly despite the typographical error in the 

consent order. In addition, as Virginia states in the SIP submittal, since the consent order was 

entered in 1986, presses 6, 8, 9, 10 and 11 and Extruder Number 4 have been dismantled and 

removed. Thus the requirements related to these units which were in the consent order are not 

included in the permit’s requirements. However, this removal reflects decreased emissions 

potential from the facility. EPA agrees with Virginia that the changes from the consent order (to 

the permit) will have no effect on VOC emissions as the prior formula included a typographical 

error and the other change reflects removal of units. 

VADEQ’s SIP revision submittal seeks to remove the prior Reynolds consent order included in 

the SIP and replace it with nearly identical VOC RACT requirements now contained for the 

Reynolds’ plant in a state operating permit. Including the permit in the SIP will continue to 

implement RACT requirements for the plant, a major source of VOCs as required by sections 

172 and 182(b) of the CAA. The permit established control technology and other requirements 

for the control of VOC emissions from the Reynolds’ plant in the Richmond Area. The permit 

incorporates only the conditions of the consent order, along with general permit conditions 

relating to testing, right of entry, and change of ownership. All operational requirements are 

limited in scope to those required by the consent order approved into the Commonwealth’s SIP 

on June 6, 1996 (61 FR 29963). EPA agrees with Virginia that the minor administrative change 

to the formulas described above and to the removal of old units will have no impact on facility 

operation, air quality or VOC emissions as the change corrects the transposition of numbers 

within the prior consent order and removes units. 

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

Virginia’s SIP submittal requests removal from the SIP of a consent order which addressed VOC

RACT for Reynolds and inclusion in the SIP of a federally enforceable state operating permit to 

continue to address VOC RACT for the facility, making only minor, administrative corrections to 

control emissions of VOCs from Reynolds. EPA believes that this SIP revision satisfies all 

requirements for an acceptable SIP and continues to address RACT for VOC for Reynolds 

pursuant to CAA requirements in sections 172 and 182(b). Consequently, EPA’s approval of the 

SIP revision is recommended. Including the permit within the Virginia SIP will ensure continued

control of emissions of VOCs from Reynolds Consumer Products LLC – Bellwood Printing 

Plant, which will reduce the formation of ozone, and thereby protect public health and welfare.