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Imation

Authority to Construct

March 18, 1992

Mr. Michael J. Falco, Senior Environmental Engineer
The 3M Company
P.O. Box 33331, Bldg. 21-2W-05
St. Paul, MN  55133

RE:  Authority to Construct #0029-220

Dear Mr. Falco:

This is Ventura County Air Pollution Control District Authority to Construct #0029-220, effective on the above date.  You are hereby authorized to construct the following items at the 3M Company Data Storage Products Division, South Lewis Road, Camarillo:

      Replace the existing 6 bed carbon adsorption system, adsorbers A01, A02, A03, A04, and D1/D2, with a "Rekusorb Carbon Adsorption/Nitrogen Desorption Plant" with a nominal flow rate of 60,000 CFM and adsorbes identified as 1A, 1B, 2A, and 2B.  The new adsorbers are to be operated as parallel pairs 1A/1B and 2A/2B, in parallel, with one common exhaust stack.
Subject to the Following Conditions:

1. The Permitted Emissions of reactive organic compounds (ROC) from the coater lines and other processes vented to the carbon adsorption system are expected to decrease as a result of installing the proposed control system.  The 3M Company may, therefore, be eligible for an Emission Reduction Credit (ERC).  The actual value of the decrease will be determined using historical data, Coater Line 41 post installation test results, and the results from the compliance verification testing required by this Authority to Construct.  This information shall be submitted with the Permit to Operate application for the new carbon adsorption system.  In order for the ERC request portion of the application to be complete, the 3M Company must quantify the amount of emission reductions requested and submit the test data, calculations, and assumptions used to support this request.

2. This replacement activity is subject to the New Source Performance Standard (NSPS) in Title 40 of the Code of Federal Regulations, Part 60, Subpart A - General Provisions and Subpart SSS - Standards of Performance for Magnetic Tape Coating Facilities.  This NSPS is incorporated by reference in APCD Rule 72.  All references to 40 CFR 60 in this Authority to Construct are references to this NSPS.  NSPS are applicable because the control device is being replaced subsequent to the NSPS regulated modification of Coater Line 41 (40 CFR 60.712(b)(2)(ii)).

3. Pursuant to 40 CFR 60.713(a)(2), prior to replacing the existing carbon adsorption system, the 3M Company shall demonstrate that the applicability requirements is 40 CFR 60.712(b)(2) have been established.  This demonstration, conducted in accordance with 40 CFR 60.713(b)(5), shall show that the total enclosure device has been installed and that all VOC emissions from the total enclosure are ventilated to the existing control device.  Information and data obtained from the Coater Line 41 testing as a part of Permit to Operate Application No. 0029-141 may be used to comply with this condition.

4. Whenever at least one coater is operating, the new proposed control system shall reduce emissions of ROC, as measured in the solvent laden air duct, by at least 95%, before release to the atmosphere, pursuant to 40 CFR 60.712(b)(2)(ii).  Such demonstration shall be made using the procedures of 40 CFR 60.713(b)(5).

In order to comply with this condition, the 3M Company shall maintain a continuous in-stack emissions monitor as required by Condition Nos. 9 and 10.  Pursuant to 40 CFR 60.7171(d)(4)(ii)(B), if the control efficiency of any bed of the carbon adsorption system is measured or calculated to be less than 95% during any 72 hour (3 day) period of coating operation, then the operation of the coating activity is in violation of 40 CFR 60, APCD Rule 72, and this Authority to Construct.

5. For all periods when ROC emissions are vented to the new control device, the new carbon adsorption system shall meet a 90% control requirement calculated as a single 168 hour rolling average, inclusive of both coater operating periods and no coater operating periods.

In order to comply with this condition, the 3M Company shall maintain a continuous in-stack emissions monitor as required by Condition Nos. 9 and 10.  If the control efficiency of the carbon adsorption system is measured or calculated to be less than 90% during any single 168 hour period of coating operation and no coating operation, then the operation of the coating activity is in violation of this Authority to Construct.

6. Whenever at least one coater is operating, the new proposed control system shall reduce emissions of ROC, as measured in the solvent laden air duct, by a combined capture and destruction efficiency of no less than 90%, averaged over a rolling 24 hour period, before release to the atmosphere.  This condition is applied pursuant to APCD Rule 74.3, "Paper, Fabric and Film Coating Operations".

In order to comply with this condition, the 3M Company shall maintain a continuous in-stack emissions monitor as required by Conditions Nos. 9 and 10.  If the control efficiency of the carbon adsorption system is measured or calculated to be less than 90% during any single 24 hour period of coating operation, then the operation of the coating activity is in violation of APCD Rule 74.3.

7. The 3M Company shall demonstrate or address the requirement of 40 CFR 60.713(c) that the 95% control efficiency will be maintained during coater line startups and shutdowns.

8. The application states that the control system is capable of complying with the 95% control efficiency requirement, even if only one adsorber system is operating and handling all of the air flow.  An adequate demonstration test is required if the 3M Company wishes to maintain this option.  The necessary testing should be addressed in the test plan required by Condition No. 13.

9. In accordance with 40 CFR 60,714(c)(2), the 3M Company shall install, calibrate, maintain, and operate, in accordance with manufacturer's specifications, a continuous emissions monitoring system (CEMS).  The CEMS shall continuously measure and record the concentration level of organic compounds in the solvent laden air duct, the exhaust stack, and the outlet concentration from each in-service carbon adsorption bed.  Continuous measurement is defined as measuring each required monitoring point at least once every 15 minutes.

10. The CEMS shall be designed and operated to provide the following data or information immediately upon demand for the most current data and in a permanent electronic record with a hard copy printout upon request:

      a. the most recently calculated value of the adsorption efficiency of each carbon adsorption vessel.
e. the ROC concentrations in ppmv in the solvent laden air duct,   in the exhaust duct to the atmosphere from the carbon     adsorption system, and the exhaust from each of the operating                 adsorber beds.

f. an audible, visual, or electronic alarm system that   automatically alerts the operator and makes a permanent record       should the carbon adsorption control efficiency fall below the       95% requirement of 40 CFR 60.717(d)(4)(ii)(B) and a second     alarm and permanent recording should the control efficiency     fall below the 90% requirement, based on a rolling 24 hour     average, of APCD Rule 74.3, and the 90% requirement, based on   a rolling 168 houraverage, of this Authority to Construct.

11. This Authority to Construct does not authorize any increases in fuel consumption or changes to the existing Permit to Operate except where reference to adsorber beds are made.  The operator shall continue to comply with the conditions of the existing Permit to Operate.

12. Pursuant to 40 CFR 60.8, the 3M Company shall demonstrate compliance by source test utilizing the methods and procedures of 40 CFR 60.715.  The source test for each adsorber vessel shall consist of three separate runs.  Each run shall coincide with one or more complete adsorption cycles pursuant to 40 CFR 60.715(b)(2).

13. At least 30 days prior to testing, the 3M Company shall submit a test plan indicating the test procedures to be used; the locations of the sample collection points; how the CEMS will be monitored and compared to the measured values during the performance test; the name of the testing contractor; what special testing is required to demonstrate compliance during shutdowns, startups, and while only one adsorber system is operating; how plant operations will be recorded and coordinated during the test; and how the results will be used to demonstrate compliance.  The test plan shall also include a monitoring plan for the total enclosure pursuant to 40 CFR 60.714(h).  Testing shall not start until the test plan is approved.

14. Prior to performing any testing, the 3M Company shall arrange for a mutually acceptable test schedule with the Engineering Section of the APCD.  An APCD representative shall be allowed to observe the tests.

15. 3M shall provide a procedure subject to APCD approval, including the manufacturers specifications, for calibrating and maintaining the hydrocarbon analyzer(s), and a copy of the span and zero gases' certified analyses.

16. The source test report, resulting from the compliance testing, shall be submitted to the APCD and the EPA Region IX within 45 days of the test date.  Pursuant to 40 CFR 60.717(a), the average values of the monitored parameters measured at least every 15 minutes and averaged over the period of the performance test shall be submitted with the results of the performance test.

The test report shall include a summary, showing calculations and compliance with the conditions of this Authority to Construct and the appropriate sections of 40 CFR 60.

The 3M Company may, at this time, submit a new proposed Camarillo Operating Procedures (COP), for APCD approval, for monitoring ROC emission compliance with APCD Rule 74.3, APCD Rule 72 (NSPS), Permit to Operate No. 0029, and this Authority to Construct.  This COP must be as stringent or may be more stringent than the appropriate ROC emission limitations.  The proposed COP shall include sufficient information and analyses for the APCD to evaluate these requests.

17. The 3M Company shall include with the test report, the manufacturer of the selected CEMS, the CEMS reported accuracies, and methods and frequencies of calibration.

18. The 3M Company shall demonstrate compliance of the carbon adsorption system, continuing acceptable operation of the CEMS, and the relative accuracy of the CEMS every two calendar years via a source testing procedure mutually acceptable to the 3M Company and the APCD, subject to the APCD approval.

19. The 3M Company shall maintain the following records for the previous two years.  These records shall be made available to APCD personnel upon request.

      a. Permanent records of the data recordings from the CEMS and the periods of CEMS calibration and maintenance (40 CFR 60.714(c)(2)).

      b. The records of the data from the total enclosure monitoring system pursuant to 40 CFR 60.714(h).

      c. The records of adsorber maintenance, records of adsorber down-time and reason, and any modifications performed to the control system (40 CFR 60.714(i)).

      d. The records of the measurements and calculations for the total enclosure as required by 40 CFR 60.713(b)(5).
20. The 3M Company shall submit the following reports and notices to the Ventura County APCD and EPA Region IX:
      a. Pursuant to 40 CFR 60.717(d)(4)(ii), quarterly reports shall be submitted detailing all three day rolling averages of each adsorber vessel when the efficiency falls below 95% and pursuant to 40 CFR 60.717(d)(8), quarterly reports shall be submitted detailing all three hour periods (during actual coating operations) during which the total enclosure monitoring device readings vary by 5% or more from the average value measured during the most recent performance test that demonstrated compliance.  Pursuant to 40 CFR 60.717(e), if no reportable exceptions to the 95% control requirement of 5% variation requirement have occurred, this information shall be reported on a semi-annual basis.  These reports shall be postmarked within 30 days of the end of the reporting period in accordance with 40 CFR 60.717(h).

      b. The 3M Company shall report o the VCAPCD anytime the CEMS indicates that the 95% (based on the 72 hour (3 day) rolling averages of all the individual adsorption vessels) control efficiency requirement, 90% (24 hour average) control efficiency requirement, or 90% (168 hour average) control requirement has not been achieved, by following the reporting requirements of the breakdown procedure discussed in District Rule 32, Breakdown Conditions; Emergency Variances.

      c. This replacement activity is subject to New Source Performance Standards (NSPS) in 40 CFR, Part 60, Subparts A and SSS.  All notifications and reports required for this facility under NSPS (40 CFR 60.7 and 40 CFR 60.717) shall be forwarded to the Ventura County APCD and the Environmental Protection Agency Region IX.
Your application for an Authority to Construct (dated April 16, 1991) was received by this office on April 26, 1991 and was considered complete on May 23, 1991.

The granting of this permit signifies that the proposed equipment have been evaluated based on the information provided with your application.  It does not, however, either grant or imply an APCD endorsement of the equipment; nor does it guarantee compliance with APCD Rules and Regulations.  Prior to construction completion, application for an APCD Permit to Operate must be filed.  Compliance of the source will be verified through a visual inspection and source test results.

We are enclosing a receipt for your payment in the amount of $3,386.56, which was received with your application.  Pursuant to Rule 42, your application filing fee is $400.00 and the permit processing fee is $2,986.56.

Please post this Authority to Construct reasonably close to the construction site and accessible to inspection personnel, in accordance with Rule 19.  This Authority to Construct will become void if construction has not begun within one year.

Contact Bill Flynn of the Engineering Section at (805) 645-1419 if you have any questions.

Sincerely,

Richard H. Baldwin
AIR POLLUTION CONTROL OFFICER

by:



_______________________________________
Karl E. Krause, Manager
Engineering Section

KZ0029

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