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Imation

Draft Permit to Operate

Page 1 of 20 DRAFT PERMIT

March 26, 1996
Ventura County Air Pollution Control District

669 County Square Drive
Ventura, CA 93003

(805) 645-1401

DRAFT PERMIT TO OPERATE

Number 0029 Valid January 1, 1996 to December 31, 1996

This Permit Has Been Issued To The Following:

Company Name / Address: Facility Name / Address
3M Company 3M Data Storage Tape Technical Division
P.O. Box 33331 Bldg. #41-01-05 350 S. Lewis Rd.
St. Paul, MN 55133 Camarillo, CA 93012

Permission Is Hereby Granted to Operate The Following:

Coating Dispersion Application/Drying Equipment Used for Magnetic Tape Production, And Consisting Of:

4 - Enclosed Magnetic Tape Coating/Curing Lines (Designated as 41, 42, 43, and 44, with 41 being the easternmost line). Each magnetic tape coating/curing line enclosure consists of a coater room and a drying/curing oven which exhaust to the ROC Control/Recovery System.

Coater Line 41 is equipped with a continuous airflow monitoring system to ensure that the line continues to meet total enclosure requirements. Airflow at Coater Line 41 is monitored at the coater enclosure air supply duct, the oven air supply duct, and the oven exhaust duct.

Coating Dispersion Compounding Equipment, Located in The Compounding Room, And Consisting Of The Following Types Of Equipment:

Ball Mills, Sand Mills, Shaker Mills, Mixing Kettles, Resin Kettles, Homogenizers, and Associated Pumps.

Each mixing kettle is equipped with a conservation vent (pressure/vacuum release valve) and lip exhausts which are routed to the ROC Control/Recovery System.

The compounding room is equipped with room vents (EF-13 and EF-14) which are routed to the coater oven supply duct, which in turn leads to the ROC Control/Recovery System.

Coating Dispersion Final Preparation, Located In The Tunnel Room, And Including The Following Equipment Which Is Exhausted To The ROC Control/Recovery System:

1 - Solvent Drum Hook-Up Vent System (F-19)
1 - Cold Solvent Wash Tank, with overhead exhaust (F-18)
1 - Tunnel Room Vent System (T-1, F-15, EF-22)
1 - Tunnel Room Vent System (T-2, T-3)

Coating Dispersion Storage Room, Consisting Of:

1 - Or More Coating Dispersion Storage Tanks, of less than 5,000 gallon capacity

Each storage tank is equipped with a conservation vent (pressure/vacuum relief valve) which exhausts to the ROC Control/Recovery System.

The coating dispersion storage room is equipped with room vent (PRE-12) which exhausts to the atmosphere.

Contaminated Soil Vapor Extraction System, Consisting Of:

1 - Or More Vapor Extraction Wells
1 - Blower, MD Pneumatics Model 5511, 25 HP, 400 cfm capacity

Exhaust from the vapor extraction wells is routed to the solvent laden air duct which leads to the ROC Control/Recovery system.

ROC (Reactive Organic Compound) Control/Recovery System, Consisting Of:

1 - Rekusorb Carbon Adsorption/Nitrogen Desorption/Solvent Recovery System, with a nominal flow rate of 60,000 CFM, and four carbon adsorption vessels identified as A1, A2, B1, and B2, operated as parallel pairs A (1 or 2) / B (1 or 2), or singly, with one common exhaust stack
1 - Solvent Recovery Storage Tank Farm, each with a capacity of less than 5,000 gallons, and each tank exhausting to the ROC Control/Recovery System
1 - Or More Distillation Columns, which exhaust to the ROC Control/Recovery System

A continuous emissions monitoring system (CEMS) is used to monitor the efficiency of the carbon adsorption system by monitoring the concentration (in ppmv) of total hydrocarbons at the following locations:

a) The solvent laden air duct;
b) The exhaust stack for carbon adsorption vessels A1 and A2;
c) The exhaust stack for carbon adsorption vessels B1 and B2; and
d) The common exhaust stack for the four carbon adsorption vessels.

One total hydrocarbon analyzer monitors emissions at the solvent laden air duct while another monitors emissions at the carbon adsorption exhaust stacks.

Emissions which are routed to the ROC Control/Recovery system are routed from the applicable local exhaust system to either a 36" duct or a 60" duct. These two ducts combine to form the "solvent laden air duct" which leads to the ROC Control/Recovery system.

Emissions are routed to the 36" duct from the following sources:

a) The solvent drum hook-up vent (F-19), overhead cold solvent wash tank vent (F-18), and T-1, F-15, F-18, and EF-22 tunnel room exhaust;
b) All conservation vents at the dispersion holding tanks in the dispersion storage room;
c) All conservation vents from compounding room mixture kettles; and
d) The solvent recovery storage tank farm and distillation column vents associated with the solvent recovery system.

Emissions are routed directly to the 60" duct from the following sources:

The four coating/curing line enclosure exhausts

Emissions are indirectly routed to the 60" duct from the following sources:

a) The T-2 and T-3 tunnel room exhausts via duct E-14 which then joins duct EF-13; and
b) All compounding room mixing kettle lip exhausts (EF-13).

Exhaust from these sources is routed to the four coating line oven air supply ducts and then exits the four oven exhaust ducts to the common 60" duct.

Emissions are routed directly to the solvent laden air duct from the following sources:

Vapor extraction wells

Wet Scrap Drying System, Consisting Of:

1 - Wet Scrap Dryer, Solidaire SJS 24-14

Boilers, Consisting Of:

1 - Nebraska Boiler, Model NS-C-44, identified as boiler No. 3, 39.3 MMBTU/Hr capacity, equipped with a Faber low NOx burner, Model WB-1-20FGR, and flue gas recirculation, fired on natural gas or standby No. 2 fuel oil

1 - Murray Boiler, Model M64-C-13, identified as boiler No. 1 and standby unit for boiler No. 3, 28.6 MMBTU/Hr capacity, equipped with a Faber low NOx burner and flue gas recirculation, fired on natural gas or standby No. 2 fuel oil

Printing Operations, Consisting Of:

1 - Or More Videojet Inkjet Printers, Model Excel 100, utilizing air drying method, with no ROC control equipment

1 - Or More Letterpress Printers, using only inks and cleanup materials that do not contain any ROCs or exempt organic compounds


This Permit Has Been Issued Subject to the Following Conditions:

1. Permitted Emissions:
Tons/Year
Pounds/Hour
Reactive Organic Compounds
Nitrogen Oxides
Particular Matter
Sulfur Oxides
Carbon Monoxide
256.88
8.34
0.51
0.96
5.73
331.31
5.57
0.56
20.07
1.39

2. Applicability of NSPS Subpart A and Subpart SSS
3. Emissions Limits for The Four Magnetic Tape Coater Lines
4. Emissions Limit for Coater Line 41
5. Compound Room And Tunnel Room Emission Limits
6. Requirement for Proper Operation Of The Rekusorb Control System
7. ROC Control Efficiency Requirement - Based on NSPS
8. ROC Control Efficiency Requirement - Based on Rule 74.3
9. Web Handling Limit For The Coating Lines
10. Coater Line 41 Total Enclosure Requirements
NSPS Requirements For Coating Mix Preparation Equipment
12. CEM Operating Requirements - ROC Control System
13. Data Requirements For Monitoring Associated With Magnetic Tape Production
14. Requirement For Periodic Source Testing Of ROC Emissions From Magnetic Tape Production Operations
15. Solvent Restrictions For Magnetic Tape Coating
16. Minimizing Emissions From Drums In The Tunnel Room
17. Minimizing Emissions At The Cold Solvent Wash Tank
18. Minimizing Emissions From Containers And Mixing Equipment
19. Magnetic Tape Production Clean-Up Activities
20. ROC Control System In A Single Carbon Bed Mode
21. Monitoring, Recordkeeping, And Reporting Requirements
22. COP Procedures For ROC Emissions From Magnetic Tape Production

23. Applicability Of APCD Rule 74.15 To The Boilers
24. Prohibition On Simultaneous Operation Of The Two Boilers
25. Fuel Consumption Limits On The Boilers
26. Requirement for Periodic Source Testing Of The Boilers
27. Flue Gas Recirculation Parameters
28. Vapor Extraction System Requirements
29. Inkjet Printing And Associated Cleanup
Material
Maximum VOC In Grams Per Liter (Lbs/Gal), As Applied
Annual Limit
(Gallons)
Inks
Cleanup
815 (6.80)
815 (6.80)
932
45
30. Letterpress Printing And Associated Cleanup
Within ten days after receipt of this permit, the applicant may petition the Hearing Board to review any new or modified condition on the permit (Rule 22).

This permit, or a copy, shall be posted reasonably close to the subject equipment and shall be readily accessible to inspection personnel (Rule 19). This permit is not transferable from one location to another unless the equipment is specifically listed as being portable (Rule 20).

In reliance upon the statement of the applicant that operation of the equipment described herein shall meet the requirements as specified in the Rules and Regulations of the Air Pollution Control District, permission is hereby granted to operate; provided, however, the permission granted hereby shall not be construed to permit said equipment to operate in violation of any applicable State or Federal emission standard or Rules and Regulations of the District.

For:

Karl E. Krause, Manager
Engineering Section
Richard H. Baldwin
Air Pollution Control Officer



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