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Imation

Pre-Draft Title V Permit - Section II

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT

Section II Permitted Emissions, Specific Applicable Requirements, and Other Permit Conditions


A. Permitted Emissions Table

The following are site-wide caps on air pollutant emissions:

VOC 150 tons per 12 month period
NOX 8.34 tons per 12 month period
CO 30 tons per 12 month period
PM <15 tons per 12 month period
SO2 <15 tons per 12 month period

Additionally, to sustain non-major source status for hazardous air pollutants (HAP), the site-wide caps are less than 25 tons per year of total HAP and less than 10 tons per year of any single HAP. Imation may elect to relinquish non-major source status at some future date. To do so, you must give advance notice of your intention and the date on which this will occur (see monthly reporting requirements in Section II.E.1.a). Upon that date, the HAP caps no longer apply and Imation Camarillo will be subject to the MACT standard for magnetic tape manufacturing (40 CFR part 63, subpart EE) and associated requirements in the Part 63 General Provisions (40 CFR Part 63 Subpart A).

The site-wide caps are effective upon issuance of this permit and apply to each 12 month period of operation (rolling monthly). To determine compliance with the emissions caps, you will calculate every month the aggregate emissions of VOC, HAPs, NOx, CO, PM, and SO2 for the previous 12 month period, according to the procedures of subsection II.C.3.

If you request to emit above the VOC, NOX, CO, PM, or SO2 caps, VCAPCD Rule 26 will apply and you must obtain offsets for any emission increases above the relevant cap. However, if a pollution control device is installed and causes collateral emissions of NOX, CO, PM, or SO2, such collateral emissions will not be counted in determining compliance with any cap. The collateral emissions still must be offset, and you must source test/monitor and keep records to document the amount of collateral emissions and the offsets required. Collateral emissions of VOC are counted toward compliance with the VOC cap.

B. Specific Applicable Requirements

The federal new source performance standards and hazardous air pollutant standard and selected Ventura County requirements that currently apply to existing operations, or will apply to new or modified, coating facilities emitting VOC or HAP at the Camarillo site have been streamlined into a single set of requirements that assures compliance with all. The streamlining exercise showed that current applicable requirements (40 CFR Part 60 Subpart SSS and Ventura County APCD Rules 52, 53, 74.3, 74.6.1) and future or potential applicable requirements (40 CFR Part 63 Subpart EE, 40 CFR Part 60, Subparts Kb, RR, TT, and VVV, and Ventura County APCD Rule 71.2) can be met by the distilled requirements in this section (with the addition of the requirements in Section IV for equipment that is not currently part of the Camarillo site). The requirements essentially reduce to the pertinent sections of 40 CFR Part 63 Subpart EE and associated General Provisions (Part 63 Subpart A), with some modification (for example, to account for the fact that subpart EE does not address VOC emissions), and a few selected additions from subsumed standards.

Because Imation is subject to a standard of performance under 40 CFR Part 60, the associated General Provisions (Subpart A) from Part 60 also apply. However, certain sections of the Part 60 General Provisions have counterparts in the Part 63 General Provisions, and the streamlining analysis referred to above has shown that requirements in such sections can be met by complying with the Part 63 General Provisions. Therefore, the requirements in Part 60 General Provisions sections 60.7, 60.8, 60.11, 60.12, 60.13, 60.18, and 60.19 are streamlined under the Part 63 General Provisions incorporated in this permit.

Additional specific applicable requirements in this section, not stemming from the streamlining exercise, proceed from the terms of the Project XL Final Project Agreement or are federal or district requirements for other types of sources (such as boilers).

1. Streamlined Applicable Requirements for Coating Operations

(a) Applicability

The streamlined requirements of this section (II.1) apply to:


(i) all existing VOC and/or HAP emitting equipment or operations subject to 40 CFR part 60, subpart SSS (NSPS for magnetic tape coating facilities) and 40 CFR part 63, subpart EE (MACT standard for magnetic tape manufacturing), and
(ii) to the extent not covered by (i), any additional existing VOC and/or HAP emitting equipment or operations listed below [and defined in 40 CFR §63.702(a)] and associated with magnetic tape manufacturing operations at the Camarillo facility:
- solvent storage tanks
- mix preparation equipment
- coating operations
- waste handling devices
- particulate transfer operations
- wash sinks for cleaning removable parts
- cleaning involving the flushing of fixed lines
- wastewater treatment systems
- condenser vents associated with distillation and stripping columns in the solvent recovery area, but not including the vent on a condenser that is used as the add-on air pollution control device.

(b) Standards for VOC and HAP

(i) Standard for each coating operation, solvent storage tank, piece of mix preparation equipment, waste handling device, condenser vent in solvent recovery, wash sink for cleaning removable parts, and cleaning involving the flushing of fixed lines. You must limit gaseous HAP and VOC emitted from each piece of equipment or operation by an overall HAP and VOC control efficiency of at least 95 percent [40 CFR §63.703(c) and (c)(1), §63.703(f)(1)(i), and §63.703(f)(2)]. For periods when coating operations are not occurring, the remaining emitting equipment (solvent storage tanks, mix preparation equipment, waste handling devices, condenser vents in solvent recovery, wash sinks, and flushing of fixed lines) may, instead of the overall 95 percent control efficiency requirement:

- be vented to the SRU that, in conjunction with capture equipment or ductwork, is designed to achieve an overall VOC/HAP control efficiency of at least 95 percent for the emissions from the coating operation; and
- meet an alternate outlet concentration limit at the exhaust of the SRU, established according to the requirements and procedures in Section II.D.1.d. [40 CFR §63.703(i)]
(ii) Standard for Particulate Transfer Operations
You must direct emissions from particulate HAP transfer through a hood or enclosure to a baghouse that exhibits no visible emissions while controlling HAP emissions from particulate HAP transfer. [40 CFR §63.703(d)(2)]
(iii) Work Practice Standard for Mix Preparation Equipment

You must ensure that mix preparation equipment covers are closed at all times except when adding ingredients, withdrawing samples, transferring the contents, or making visual inspection, if such activities cannot be carried out with the cover in place. Such activities must be carried out through ports of the minimum practical size. Mix preparation equipment means the vessels, except for mills, used to prepare the magnetic coating. [40 CFR §63.705(d)(2) and 63.702(a)]
(iv) Restricted Use of Chlorinated Solvents
As a condition of this permit, based on your voluntary restriction, you must not use any chlorinated solvent or other volatile chlorinated compound in manufacturing related operations at the Camarillo facility, including for the purpose of cleaning removable parts in wash sinks and flushing fixed lines. Use of chlorinated solvents or compounds is permitted when formulated in products used for minor repairs or maintenance or general facility housekeeping.
(v) Use of Safety Devices
You may use pressure relief valves and vacuum relief valves as needed for safety purposes. [40 CFR §63.703(j)]

(c) Startups and Shutdowns

The provisions of this subsection (II.B.1) apply during periods of startup, shutdown, and whenever coating operations are taking place. [§63.701(f)]

(d) Total Enclosure(s)

For all coating operations, solvent storage tanks, waste handling devices, mix preparation equipment, wash sinks for cleaning removable parts, cleaning involving the flushing of fixed lines, and condenser vents from solvent recovery (except for any emissions from solvent storage tanks and waste handling devices which are hard-piped or hard-ducted to the air pollution control device), you must capture all VOC and HAP emissions through use of one or more total enclosures meeting the requirements of 40 CFR §63.705(c)(4)(i)(A) through (c)(4)(i)(D). Such enclosure requirements include:

- restricting natural draft openings to 5% or less of the total surface area of the enclosure;
- keeping emission sources at least four equivalent diameters away from each natural draft opening;
- maintaining an average of at least 3600 meters per hour (3.28 feet per second) inward face velocity across natural draft openings;
- the air flow through natural draft openings must be into the
enclosure at all times; and
- constructing ducts for forced makeup air and exhaust so that volumetric flow rates can be determined by test methods and procedures specified in 40 CFR §63.705(b)(4) and (5).

(e) Environmental Management System

You must develop and implement an Environmental Management System meeting the specifications in Appendix 4 of the Imation Camarillo FPA [Note: selected provisions of the Environmental Management System are incorporated as specific requirements elsewhere in this permit.]

(f) Ventura County APCD Air Toxics Requirements (State-Enforceable Only)

You must comply with the requirements of the Ventura County APCD Air Toxics "Hot Spots" Program implementing Sections 44300-44394 of the California Health and Safety Code (AB 2588).


2. Ventura County Air Pollution Control District
Rule 74.15.B.1 Applicable Requirements
Boilers, Heater Treaters, Steam Generators, and Process Heaters
NOx and CO Emission Limits
Annual Heat Input > 9,000 MMBTU
Rule 74.15, "Boilers, Steam Generators, and Process Heaters"
Adopted 11/8/94, Federally-Enforceable

Applicability:

This attachment applies to boilers, heater treaters, steam generators and process heaters with a maximum heat input rating of greater than or equal to 5 MMBTU/Hr that have operated with an annual heat input rate of greater than or equal to 9,000 MMBTU during any twelve (12) calendar month rolling period. This attachment also applies to any unit operated with an annual heat input rate of less than 9,000 MMBTU that is equipped with low NOx burners or other such equipment to comply with the NOx and CO requirements of Rule 74.15.B.1. A heat input of 9,000 MMBTU is equivalent to 90,000 therms and equivalent to 8.57 million cubic feet of natural gas at a higher heating value of 1,050 BTU/cf.

A boiler, steam generator or process heater is any external combustion equipment fired with liquid and/or gaseous fuel. A boiler or a steam generator is further defined as equipment used to produce steam or to heat water. Boiler or steam generator does not include any unfired waste heat recovery boiler that is used to recover sensible heat from the exhaust of any combustion equipment. A process heater is further defined as equipment which transfers heat from combustion gases to water or process streams. Process heater does not include any kiln or oven used for drying, baking, cooking, calcinating or vitrifying, or any fuel-fired degreasing or metal finishing equipment. Annual heat input is defined as the actual amount of heat released by fuels burned in a unit during a twelve (12) calendar month rolling period, based on the higher heating value of the fuel. The annual heat input must be calculated as the sum of the previous 12 monthly fuel use rates multiplied by the higher heating value of the fuel.

Conditions:

1. Pursuant to Rule 74.15.B.1, emissions from an applicable emission unit must not exceed the following limits:

a. Oxides of Nitrogen (NOx expressed as NO2): 40 ppmvd
b. Carbon Monoxide (CO): 400 ppmvd
These limits must be referenced at three (3) percent volume stack gas oxygen on a dry basis averaged over 15 consecutive minutes. Compliance with this condition must be verified every 24 months by source testing.
Pursuant to Rule 74.15.B.1, an applicable emission unit must be source tested not less than once every 24 months (biennially) utilizing the following methods as detailed in Rule 74.15.E:
a. NOx ARB Method 100
b. CO ARB Method 100
c. Stack Gas Oxygen ARB Method 100
Pursuant to Rule 74.15.E.2, emission tests must be conducted on units in "as-found" operating condition. However, no emission test for Rule 74.15 shall be conducted during start-up, shutdown or under breakdown conditions. Prior to conducting a biennial emissions test, permittee must notify the District Enforcement Section. Written notification must be received no less than 15 calendar days prior to the test. The emissions test report and results must be submitted to the District Enforcement Section within 45 days after the test.
Pursuant to Rule 74.15.C.2, the emission limits of Rule 74.15.B.1 shall not apply to any unit operated on alternate fuel under the following conditions:
a. Alternate fuel is required due to the curtailment of natural gas service to the individual unit by the natural gas supplier. Alternate fuel use in this case must not exceed the period of natural gas curtailment.
b. Alternate fuel use is required to maintain the alternate fuel system. Alternate fuel use in this case must not exceed 50 hours per year.
Pursuant to Rule 74.15.C.4, the emission limits of Rule 74.15.B.1 shall not apply during the cold startup of an applicable unit. For units with a rated heat input capacity of equal to, or greater than, one hundred (100) million BTUs per hour, the duration of this exemption must not exceed three (3) hours. For units with a rated heat input capacity of less than one hundred (100) million BTUs per hour, the duration of this exemption must not exceed one (1) hour.
5. Permittee must record and maintain the following information:

a. Daily records of alternate fuel consumption as required by Rule 74.15.D.3. Each record must include the type of fuel, the quantity of fuel, and the duration of the occurrence; and
b. The biennial source test report.

This information must be submitted to the District upon request.

6. If the emission unit is equipped with an external flue gas recirculation (FGR) system for the control of nitrogen oxides, permittee must also comply with the following FGR requirements:

The Murray and Nebraska boilers' flue gas recirculation linkage settings must comply with the following:
Murray Boiler Third pin setting from the end
Nebraska Boiler Connecting rod attached to the 4th hole from the end on the damper control arm and the 5th hole from the end on the cam indicator arm
In order to comply with these linkage setting requirements, you must be prepared to demonstrate to the Ventura County APCD representative, on request, that the linkages are set as required. If the settings are different, it will be a violation of this condition, unless you can demonstrate compliance with the emission limits in Condition 1 above by emissions testing pursuant to Ventura County APCD Rule 74.15.


3. Operation and Maintenance Requirements

(a) General Requirement

At all times, including periods of startup, shutdown, and malfunction, you must operate and maintain any affected source, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by relevant standards. [40 CFR 63.6(e)(1)(i)]
Determination of whether acceptable operation and maintenance procedures are being used will be based on information available to the Ventura County APCD which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR §63.6(e)(2)]

(b) Malfunctions

A conclusion of the streamlining analysis described in Section II.B is that Ventura County Rule 32 Breakdown Conditions; Emergency Variances is equivalent to the startup, shutdown, and malfunction provisions of 40 CFR 63.6(e) [except for 63.6(e)(1)(i) and (e)(2) whose requirements are included at II.B.3.a above], provided that the Rule 32 definition of breakdown is modified to include malfunction of processes and process equipment (which causes a violation of any emission limitation or restriction prescribed by VCAPCD Rules and Regulations, or by State law) and to exclude from the definition of breakdown recurrent breakdowns of the same equipment. Therefore, you must comply with the provisions of Ventura County Rule 32 for all breakdowns of air pollution control equipment, in-stack continuous monitoring equipment, or processes or process equipment. Compliance with Rule 32 (with the modified definition of breakdown as incorporated above) will be considered compliance with 40 CFR 63.6(e)(1)(ii) and 63.6(e)(3)(i) through (e)(3)(viii).

C. Emissions Monitoring and Recordkeeping

1. Monitoring and Recordkeeping Tables

Imation must comply with all monitoring and recordkeeping provisions as identified in the streamlining analysis described in Section II.B of this permit. The tables below describe specific, federally enforceable monitoring and recordkeeping requirements for equipment operated at the Camarillo facility at the time of permit issuance. Some additional monitoring and recordkeeping requirements are contained in Section II.C.2.

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT

(g) Additional requirements for the SRU CEMS. The following additional requirements apply to the FTIR-CEMS and FID-CEMS contained in Table II.C.1(f), as noted.

(i) The FID-CEMS must meet applicable requirements of Performance Specification 8 of 40 CFR Part 60, Appendix B. [40 CFR 63.704(c)(2)(i)]

(ii) The FID-CEMS must meet applicable requirements of Performance Appendix F of 40 CFR Part 60, including the requirement that quarterly audits challenge the CEMS with compounds representative of the emission stream being controlled. [40 CFR 63.704(c)(2)(i)]

(iii) Zero (low-level) and high level calibration drifts for the FTIR-CEMS and FID-CEMS must be checked at least daily and adjusted according to 40 CFR 63.8(c)(6).

(iv) The FTIR-CEMS must be operated according to the U.S. EPA Draft FTIR Protocol of 1995, U.S. EPA Draft Method 320, and U.S. EPA Draft Performance Specification 15, according to the Certification Testing performed by Rho Squared on the FTIR at the Camarillo plant on January 19 through 22, 1998.

(h) For a minimum of 5 years after each performance test, you must keep a record of all performance tests, including any associated measurements made to determine process conditions during the performance test. [40 CFR 63.7(g)(3), 63.10(b)(2)(viii) and (ix)]

(i) You must make a written applicability determination, according to 40 CFR 63.10(b)(3), at the time of promulgation of each future MACT standard which could reasonably apply to operations of the plant. Keep the applicability determination on file at the plant and submit to Ventura County APCD upon request. [40 CFR 63.10(b)(3)]

(j) Retention of Records. All records required by this permit must be retained for a period of at least 5 years from the date that the information is collected, and according to 40 CFR 63.10(b)(1) and 40 CFR 63.706(h).
3. Determination of Compliance with Emissions Caps

You must use the following procedures to determine the monthly emissions of VOC, NOx, CO, PM, SO2, and HAP. Each month the emissions for a pollutant are to be summed with the previous eleven months emissions to determine the most recent 12-month emissions of the pollutant .

(a) VOC

Procedures for Determining VOC Emissions
Emission Source	Procedure
All emission sources ducted to the existing SRU. Such sources include: coaters, coating mix preparation equipment, kettles, waste handling devices, wash tanks, compounding room, tunnel room, coating supply drums, scrap dryer, and vapor extraction system.	For each VOC emitted from the control device, the FTIR-CEMS provides an emission rate (in lbs/hr) once each cycle (approximately every 4.5 minutes). To determine monthly emissions, you must integrate these emission rates, for each VOC, over the period of one calendar month. Sum the monthly emissions for each VOC to determine total monthly VOC emissions.
Inkjet printing operations, wipe cleaning operations, QA/QC laboratory, temporary fugitives from breakdowns, and any other VOC emitting operations not ducted to a control device.	Calculate emissions of VOC from records maintained on a monthly basis which indicate the amount of all VOCs used and the VOC content, as applied or used, of each material. Assume all VOC applied or used is emitted to the atmosphere. For the QA/QC area, you must use the results of the plant's most recent AB2588 audit. For the maintenance and slitting area, you must use the results of the plant's most recent AB2588 audit.
Boilers	For natural gas: Multiply the emission factor 2.8 lbs/MMcf by the amount of natural gas (MMcf) fired in the reported month For No.2 fuel oil: Multiply the emission factor 0.2 lbs/1000 gal by the amount of No.2 fuel fired in the reported month.


(b) HAP

Procedures for Determining HAP Emissions
Emission Source	Procedure
All emission sources ducted to the existing SRU. Such sources include: coaters, coating mix preparation equipment, kettles, waste handling devices, wash tanks, compounding room, tunnel room, coating supply drums, scrap dryer, and vapor extraction system.	For each HAP emitted from the control device, the FTIR-CEMS provides an emission rate (in lbs/hr) once each cycle (approximately every 4.5 minutes). To determine monthly emissions, you must integrate these emission rates, for each HAP, over the period of one calendar month. Sum the monthly emissions for each HAP to determine total monthly HAP.
Inkjet printing operations, wipe cleaning operations, QA/QC laboratory, temporary fugitives from breakdowns, and any other VOC emitting operations not ducted to a control device.	Calculate emissions of each HAP from records maintained on a monthly basis which indicate the amount of each HAP used and the HAP content, as applied or used, of each material. Assume all HAP applied or used are emitted to the atmosphere. Sum individual monthly HAP emissions to determine total monthly HAP emissions. For the QA/QC area, you must use the results of the plant's most recent AB2588 audit. For the maintenance and slitting area, you must use the results of the plant's most recent AB2588 audit.


(c) NOx

Procedures for Determining NOx Emissions
Emission Source	Procedure
Boilers	For natural gas: Multiply the emission factor 50 lbs/MMcf by the amount of natural gas (MMcf) fired in the reported month. For No.2 fuel oil: Multiply the emission factor 20 lbs/1000 gal by the amount of No.2 fuel fired in the reported month. (d) SO2

Procedures for Determining SO2 Emissions
Emission Source	Procedure
Boilers	For natural gas: Multiply the emission factor 0.6 lbs/MMcf by the amount of natural gas (MMcf) fired in the reported month. For No.2 fuel oil: Multiply the emission factor 71.8 lbs/1000 gal by the amount of No.2 fuel fired in the reported month.


(e) PM

Procedures for Determining PM Emissions
Emission Source	Procedure
Boilers	For natural gas: Multiply the emission factor 13.7 lbs/MMcf by the amount of natural gas (MMcf) fired in the reported month. For No.2 fuel oil: Multiply the emission factor 2.0 lbs/1000 gal by the amount of No.2 fuel fired in the reported month.


(f) CO

Procedures for Determining CO Emissions
Emission Source	Procedure
Boilers	For natural gas: Multiply the emission factor 35.0 lbs/MMcf by the amount of natural gas (MMcf) fired in the reported month. For No.2 fuel oil: Multiply the emission factor 5.0 lbs/1000 gal by the amount of No.2 fuel fired in the reported month.


4. Applicability of the Compliance Assurance Monitoring (CAM) Rule

Pursuant to the requirements concerning enhanced monitoring and compliance certification under the Clean Air Act, EPA promulgated regulations to implement compliance assurance monitoring (CAM) for major stationary sources of air pollution that are required to obtain operating permits under title V of the Act (See 40 CFR Part 64). Subject to certain exemptions, the regulations require owners or operators of such sources to conduct monitoring that satisfies particular criteria established in the rule to provide a reasonable assurance of compliance with applicable requirements under the Clean Air Act.

Imation's emissions units and activities subject to emission limitations or standards proposed by EPA after November 15, 1990 pursuant to Section 111 or 112 of the Clean Air Act are not subject to CAM. Nor are the emissions caps or any other applicable requirements currently applicable to the facility. In addition, Imation will not be subject to CAM as a result of the applicable requirements for which the source is pre-approved pursuant to the alternative operating scenarios in Section IV. However, Imation is responsible for evaluating applicability of CAM and taking all necessary steps to comply with CAM for any future emissions activities undertaken at this facility that are not pre-approved in Section IV of this permit.
D. Compliance and Source Testing

As described in Section II.B of this permit, the streamlining exercise completed for applicable or potentially applicable Federal emission standards distilled down to applicable parts of 40 CFR Part 63 Subpart EE, along with applicable provisions from the Part 63 Subpart A General Provisions (as delineated in Subpart EE). This section describes the distilled requirements for Imation's initial demonstration of compliance (II.D.1) and applicable compliance and performance testing requirements for ongoing activities.

1. Initial Compliance Requirements

Initial compliance demonstration requirements stemming from 40 CFR Part 63 Subpart EE are delineated below. According to §63.705(a), you must conduct an initial performance demonstration for sources subject to standards under §63.703(c) [for solvent storage tanks, mix preparation equipment, coating operations, waste handling devices, and condenser vents in solvent recovery], §63.703(d)(2) [for particulate transfer operations], §63.703(e)(1) [for wash sinks], and §63.703(f)(1) [for equipment for flushing fixed lines]. EPA has deemed certain actions already taken by Imation to be sufficient to warrant a waiver of performance testing . The status of initial compliance demonstrations and demonstrations yet to be made follow for each source type. (a) Total Enclosure and SRU Demonstrations. For Total Enclosures 1, 2, 3, and 4, the compliance demonstration option chosen by Imation is that of §63.705(c)(4), which requires demonstration of a total enclosure around the emission points and control of all captured emissions by a device meeting 95% control efficiency. All 4 total enclosures are ducted to a single solvent recovery unit (SRU).

(i) EPA is waiving the requirement for an initial performance test of the SRU. This waiver is based on previous source testing completed by Imation, as well as the continued operation of the SRU at greater than 95% control efficiency, as monitored by the FID-CEMS. 40 CFR 63.7(e)(2)(iv) provides EPA with authority to waive the requirement for performance testing where, "the owner or operator of an affected source has demonstrated ... to the Administrator's satisfaction that the affected source is in compliance with the relevant standard." [See EPA Region 9 letter from Dave Howekamp to VCAPCD, dated ______, 1999 approving this waiver.]

(ii) You must perform an initial compliance demonstration for Total Enclosures #1, #2, #3, and #4 and submit the results to VCAPCD within 180 days of permit issuance, or prior to the time that you elect to relinquish the HAP emissions caps according to Section II.A, whichever occurs first. [40 CFR 63.7(a)(2)]

(iii) The criteria for approval of enclosures as "total enclosures" [40 CFR 63.705(c)(4)(i)(A) through (c)(4)(i)(D)] are met by enclosures designed with no natural draft openings (NDOs). There are no natural draft openings in Total Enclosures #1, #2, #3, and #4. Therefore, as the initial compliance demonstration and within 180 days of issuance of this permit, you must inspect and document that there are no NDOs in each of the 4 total enclosures.

(b) For the baghouse that services the milling and charging floors, you must establish through engineering calculations the minimum pressure drop across the baghouse that ensures that particulate HAP are being captured by the control device. This value must be submitted within 180 days of issuance of this permit [40 CFR 63.7(a)(2)]. The requirement to perform initial visible emissions testing according to 40 CFR 63.705(g)(2) on sources subject to §63.703(d)(2) has been waived per Imation's demonstration under §63.7(e)(2)(iv) and 63.705(a)(2), and the requirement that the baghouse is exhausted to the SRU [see also Section II.C.2.a of this permit]. [See EPA Region 9 letter from Dave Howekamp to VCAPCD, dated ______, 1999 approving this waiver.]

(c) Emissions from wash sinks and flushing of fixed lines are within total enclosures ducted to the SRU. Therefore, for wash sinks and flushing of fixed lines, the initial compliance demonstration is met by completing the requirement of Section II.D.1.a above. [40 CFR 63.705(e)(3) and 63.705(f)(2)]

(d) To establish an alternate outlet concentration limit as provided in II.B.1.b.i, you shall collect FID-CEMS VOC concentration data when the coating operation is not occurring. During the period in which this limit is being established, the control device must be operated in accordance with good air pollution control practices and in the same manner as it was operated to achieve the emissions limitation for coating operations. [40 CFR 63.704(b)(11)(ii)]

(i) You may establish more than one alternate outlet concentration, if necessary to address various operating conditions when no coating is occurring. [40 CFR 63.704(b)(11)(i)]

(ii) You must express the alternate outlet concentration(s) as a 72-hour rolling average of total VOC concentration, with a rolling period of no greater than 24 hours [40 CFR 63.704(b)(11)and 63.704(c)(3)(iii)]

(iii) You may establish alternate outlet concentration(s) for various plant operating conditions . You may revise established alternate outlet concentration limit(s) by following the same procedures required to establish the original alternate concentration limits, and on the basis of relevant changes in plant operating conditions, such as age of the carbon, type of carbon, and product formulations (including type and quantity of each solvent; physical characteristics of each solvent). Revised alternate concentration limits must meet the requirements of Section II.B.1.b.i.

(iv) Alternate outlet concentration(s) shall be established pursuant to the above provisions and must be submitted to the District in accordance with Section II.E.2.i, within 180 days of permit issuance. [40 CFR 63.7(a)(2)]

(v) Initial establishment of alternate outlet concentration limits, as well as any subsequent revised alternate concentration limits will be processed by VCAPCD using minor permit modification procedures. (e) For all storage or mixing tanks and condenser vents from the sparge bin and wet scrap dryer that are hard-piped or hard-ducted to the SRU, the initial compliance demonstration is fulfilled by visual inspection verifying that the equipment is vented to the SRU. This inspection must be performed within 180 days of issuance of this permit, and results of this inspection need not be submitted to the permitting authority. The requirement to conduct a performance test of the SRU is being waived according to Section II.D.1.a of this permit. [40 CFR 705(d)(1)(i) and (ii), 40 CFR 63.7(a)(2)]

In addition to the requirement above, as part of the initial compliance demonstration for mix preparation equipment, you must ensure that covers are closed at all times except when adding ingredients, withdrawing samples, transferring the contents, or making visual inspection when such activities cannot be carried out with the cover in place. Such activities must be carried out through ports of the minimum practical size. [40 CFR 63.705(d)(2)]

(f) CMS Performance Evaluations. The requirement for an initial performance test of the FTIR, FID, and air flow meter of the SRU is waived. This waiver is based on testing by Imation of the FTIR and FID on January 19 to 22, 1998, and the air flow meter on June 11, 1997. 40 CFR 63.7(e)(2)(iv) provides EPA with authority to waive the requirement for performance testing where, "the owner or operator of an affected source has demonstrated ... to the Administrator's satisfaction that the affected source is in compliance with the relevant standard." [See EPA Region 9 letter from Dave Howekamp to VCAPCD, dated ____, 1999 approving this waiver]

2. Compliance and Performance Testing Procedures

(a) Unless otherwise specified, compliance demonstrations and testing must be performed according to EPA reference test methods [63.705(b)]

(b) A Quality Assurance Plan must be developed before conducting a required performance test, according to 40 CFR 63.7(c)(2). If requested by the Agency, the plan must be submitted 60 days in advance of the test and approved, according to 40 CFR 63.7(c)(2) and (3)

(c) The agency must be notified of performance tests according to Section II.E.2.d.

(d) Performance audit samples must be analyzed during each performance test, according to 40 CFR 63.7(c)(4).

(e) Adequate testing facilities must be provided according to 40 CFR 63.7(d).

(f) Testing conditions, and other aspects of performance tests must be conducted according to 40 CFR 63.7(e). Emissions occurring during any startups or shutdowns during performance testing must be included in test samples, as startup and shutdown are normal operation for this source. [40 CFR 63.705(i)]


E. Reporting, Notifications and Other Submittals

As a result of the streamlining exercise described at the beginning of this section (II) of the permit, applicable reporting requirements have been distilled to those of 40 CFR Part 63 Subpart EE and Subpart A (applicable parts as delineated in Subpart EE). Applicable streamlined reporting, notification, and other submittal requirements are cited and described below (in Section II.E.2). Reporting requirements stemming primarily from the Final Project Agreement under Project XL are delineated in Section II.E.1.

1. Monthly Report

(a) Submit to VCAPCD and EPA Region 9, within 30 days of the end of each calendar month, a monthly report containing the following information:

(i) for the reported month, the facility-wide emissions of VOC, NOx, SO2, CO, PM, and HAPs, as determined using the procedures in Section II.C.3 of this permit [FPA Section II.A.3.c];

(ii) the cumulative facility-wide emissions for the latest twelve month period of VOC, NOx, SO2, CO, and HAPs, as determined using the procedures of Section II.3.C of this permit, and including a comparison of these emissions to the permitted annual emissions caps [FPA Section II.A.3.c];

(iii) all of the daily 72 hour rolling average control device efficiencies and alternate outlet concentrations required to be monitored and documented by this permit;

(iv) a description of any emission-related modifications to the facility that were completed over the last month or are anticipated to be completed by the time the monthly report is submitted, as well as any such planned modifications for the upcoming two months (Ventura County APCD will specify the format and information to be provided, although completed and planned modification descriptions will include estimates of any emission changes related to the modifications) [FPA Section II.A.3.c];

(v) A summary of the results of any BACT/TBACT analyses that were conducted during the reported month for proposed modifications under Section IV.F of this permit;

(vi) A summary of the results of any tiered health risk assessments that were completed during the reported month for proposed modifications under Section IV.F of this permit;

(vii) Your intention to relinquish the HAP limits contained in Section II.A, including the specific date on which this will occur;

(viii) a description of any deviations from compliance with monitored parameter requirements in Section II.C. [40 CFR 63.707(i)(1)];

(ix) time periods in which emission flow was diverted from the SRU through a by-pass line [40 CFR 63.707(i)(4)];

(x) results of the monthly inspection of the monitoring system for by-pass valves [40 CFR 63.707(i)(4)]; and

(xi) total process operating time of the reporting period [40 CFR 63.10(c)(13)].

(b) For the monthly reports submitted for the months of June and December (or more frequently pursuant to the conditions outlined in 40 CFR 63.10(e)(3)), you must include the following information in addition to that in Section II.E.2.a:

(i) A CMS Summary Report, for each CMS referenced by Table II.C.1, consisting of the information in 40 CFR 63.10(e)(3)(vi) and 63.8(c)(8) as appropriate [40 CFR 63.8(b)(3) ; 40 CFR 63.10(e)(3)(vi) and (vii); 40 CFR 63.707(i)];

(ii) An Excess Emissions and Monitoring System Performance Report. You must submit this report in addition to the CMS Summary Report only if, for a particular CMS referenced by Table II.C.1, the total duration of excess emissions or process or control system parameter exceedances for the reporting period was greater than or equal to 1% of the total operating time for the reporting period, or if for a particular CMS referenced by Table II.C.1 the CMS downtime was greater than or equal to 5% of total operating time [63.10(e)(3)(viii)]; and

(iii) A continuous monitoring system performance report consisting of the information identified in 40 CFR 63.10(e)(3)(v), 40 CFR 63.707(k)(2), and 40 CFR 63.707(i)(1).

2. Specific Reporting, Notification, and Other Submittal Requirements

(a) You must submit a single notification of compliance status to VCAPCD within 180 days of issuance of this permit which provides the results of the compliance demonstrations and inspections required in Sections II.D.1(a), (b), (c), (d), and (e), in accordance with 40 CFR 63.7(g)(1) . [40 CFR 63.7(g)(1), 9(h)(3), 9(i), 10(d)(2), 40 CFR 707(h)]

(b) Any report submitted pursuant to requirements of this permit must contain a certification by the site's responsible official that, based on information and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, and complete. [40 CFR 70.5(d)]

(c) You must notify VCAPCD in writing of your intention to conduct a performance test, including an opacity or visible emission observation if applicable, at least 60 calendar days before the performance test is scheduled to begin to allow VCAPCD , upon request, to review and approve the site-specific test plan required under Section II.D.2.b and to have an observer present during the test. Observation of the performance test is at the discretion of VCAPCD .[40 CFR 63.9(e), 63.8(e)(2), 63.8(e)(3)(iii), and 63.7(b)]]

(d) Notification of CMS Performance Evaluations. At the same time that the notification of a performance test is provided under Section II.E.2.c, you must notify VCAPCD of the date any associated CMS performance evaluation will be conducted. If no performance test is required under Section II.E.2.c, you must notify VCAPCD in writing of your intention to conduct a CMS performance evaluation at least 60 calendar days before the performance test is scheduled. [40 CFR63.8(e)(2) and 63.9(g)(1)]
You must also submit a CMS performance evaluation test plan, if requested, in accordance with 40 CFR 63.8(e)(3).

(e) Reporting Results of Source Performance Tests. Test results must be submitted to VCAPCD within 60 days and must consist of the information identified in 40 CFR 63.7(g)(1) [40 CFR 63.10(d)(2)].

(f) Reporting Results of CMS Performance Evaluations. Test results must be submitted to VCAPCD within 60 days and must consist of the information identified in 40 CFR 63.8(e)(5)(i).

(g) All monthly reports required under Section II.E must be submitted to VCAPCD and EPA. All notifications must be submitted to Ventura County APCD only, except in such cases that Imation is specifically requested by EPA to do otherwise [40 CFR 63.9(a)(4)(ii)].

(h) All reports, notification and similar relevant information must be retained for at least 5 years, with the most 2 recent years being retained on-site. All such data may be maintained on electronic format so long as it is available in a form that is suitable and readily available for expeditious review and inspection. [ 40 CFR 63.10(b)(1) ]

(i) Within 180 days of issuance of this permit, you must submit to VCAPCD the alternate outlet concentration limit(s) established pursuant to the procedures in Section II.D.1.d of this permit. To support the proposed limit(s), you must also submit the following within 180 days of issuance of this permit: [40 CFR 63.704(b)(11)(ii) and 63.707(k)(1)]

(i) The CEM data collected to establish the limit(s);

(ii) Records of when coating operations were down;

(iii) The rationale for the alternate proposed limit(s); and

(iv) A statement signed by a responsible official of the company that the control device was operated in accordance with good air pollution control practices and in the same manner it was operated to achieve compliance with the emission limitation for coating operations.


F. Preconstruction Review Requirements under Section 112(i)(1) of the Clean Air Act

Section 112(i)(1) of the CAA requires major sources of hazardous air pollutants that are subject to an emission standard under Section 112 to undergo preconstruction review by EPA (or its designee) prior to certain specified types of activity. 40 CFR 63.5 contains regulations promulgated to implement Section 112(i)(1). The preconstruction requirements contained at 40 CFR 63.5 apply to construction of a new major affected source, or to reconstruction either of an affected source or of a source such that it becomes an affected source.

For purposes of this facility, the requirements of 40 CFR 63.5 do not apply to any activity implemented under a pre-approved scenario in Section IV of this permit. None of the pre-approved activities specified in Section IV of this permit involve construction of a new major affected source, reconstruction of an affected source, or reconstruction of a source such that it becomes an affected source. Section IV does authorize construction of new magnetic tape coating equipment, however, this facility (once the HAP limits in Section II.A are relinquished) will already be a major affected source (subject to 40 CFR Part 63, Subpart EE) and the construction of additional magnetic tape coating equipment will be considered a part of this existing major affected source; it will not be considered a new major affected source. 40 CFR 63.2 defines affected source as "...the stationary source, the group of stationary sources, or the portion of a stationary source that is regulated by a relevant standard ... established pursuant to Section 112 of the Act." In addition, 40 CFR Part 63, Subpart EE states that the requirements apply to, "each new and existing magnetic tape manufacturing operation located at a major source of hazardous air pollutant (HAP) emissions." In addition, pre-approved scenarios in Section IV do not allow any activity that would constitute "reconstruction" of magnetic tape coating sources (the existing affected source), based on the definition of reconstruction contained at 40 CFR 63.2.

40 CFR Part 63.5 preconstruction review requirements would apply only if there is construction or reconstruction of a source at this facility that is subject to a standard promulgated under 40 CFR Part 63, but that is not identified in Section IV of this permit. Such construction or reconstruction is not pre-approved under this permit.

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