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VCAPCD Staff Issues with the Imation Covenant

3M Camarillo Convenant
VCAPCD Staff Issues

Demonstration of "Beyond Compliance" Still Needed

District Banking Rule Continues to Apply to Facility

ERC will be approximately 55 tpy not 100 tpy. (III.A.2)

New Source Review Rule Exemption is Too Broad (II.A.3)

Prohibition on New Laws Needs to be Rethought (V.B)

Substitute Procedure for AB2588 Needs Revision

District Needs Authority to Approve or Disapprove Monitoring and Recordkeeping Procedures

Covenant Needs to More Specifically State Which Rules Are Superceded (Or Which Still Apply)

One Time Adjustment of ROC Cap

Term Limit of Permit (V.C)

Short Term Limit on Primary Control Equipment (IV.D)

Minor Issues

(Note: Is Environmental Health aware of this process?)


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