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

DATE: July 19, 2016

SUBJECT: T echnical Support Document for Virginia ’s Approval and Promulgation of Air

Quality Implementation Plans for Control of Emission s 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 Pr ogram 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 )

. Und er 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 co ntrol of emissions of volatile organic compounds (VOCs) f o r 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 (conse nt 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 Commonwe alth of Virginia adopt and enforce a SIP , to attain and maintain the national ambient air quality s tandards (NAAQS). The SIP provide s that Virginia

must, on case

- by

- case basis, determine whether there is RACT available to reduce volatile organic compound s (VOC s ) 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 moderate2

nonattainment area. A redesignation request and maintenance plan w as sent t o EPA and approved on November 17, 1997

. 62 FR 61237

. On J uly 18, 1997, EPA promulgated an 8

- hour

ozone NAAQS. On September 22, 2004

, the Richmond A rea was classified as a marginal nonattainment area. On September 20, 2006, VADEQ submitted a reque st to redesignate the
Richmond A rea from nonattainment to attainment of the 8

- hour ozone NAAQS . On September 25, 2006, VADEQ submitted a maintenance plan for the Richm ond A rea as a SIP revision to ensure continued attainment. The redesignation request and main tenance plan were approved by

EPA on June 1, 2007

. 72 FR 30485. The maintenance plan included case

- by

- case RACT

requ irements 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
Richmon d 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 g uideline s (non

- CTG s) 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 fa cility

. 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 perm it 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 contai ns 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’ stat e 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 typogr aphical
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 as3

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 b ase d ( WB ) m aterials 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 = t otal estimated solvents the plant is capable of using if WB m aterials 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 typog raphical 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 th ese 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 n early 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 c onditions 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 w ill 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 request s 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 pe rmit to continue to address VOC RACT for the facility, making only minor, administrative corrections t o control emissions of VOCs from Reynolds. EPA believes that t his SIP revision satisfies all

requ irements 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 continue d
control of emissions of VOCs from Reyno lds Consumer Products LLC

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