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VCAPCD Staff Issues with the Imation Covenant

CAMCOUIS.DOC 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)
      Any further reduction in the cap will create an emission reduction rather than an ERC. ERC will be lower by 10% to 20% based on circumstance. (Attachment 2)

New Source Review Rule Exemption is Too Broad (II.A.3)
      Exemption is not limited to equipment reasonably related to tape coating or to equipment controlled by the carbon adsorption system

      Convenant does not commit to installing equivalent to BACT on any new equipment

Prohibition on New Laws Needs to be Rethought (V.B)
      Project XL is based on "Beyond Compliance". This concept should apply both now and in the future. Although neither current nor future rules need formally apply to 3M, the covenant should commit 3M to make emission reductions equivalent to reductions required by applicable requirements both now and in the future.

Substitute Procedure for AB2588 Needs Revision
      One ton per year trigger level for health risk assessment is much too high for many compounds (III.A.3)

District Needs Authority to Approve or Disapprove Monitoring and Recordkeeping Procedures
      For new equipment or processes, District review need not precede change

Covenant Needs to More Specifically State Which Rules Are Superceded (Or Which Still Apply)
      No upset/breakdown procedure in covenant
      No hearing board/appeal procedure in covenant
      No right of inspection in covenant
      No right to request information in covenant

One Time Adjustment of ROC Cap
      If an analysis of the FTIR data compared to the current CEM data shows either a positive or a negative bias, there should be a provision for a one time adjustment to the ROC cap as mutually agreed upon by the District and 3M (with the hearing board as the arbitrator of any dispute). (Attachment 1.A)

Term Limit of Permit (V.C)
      The permit should have a term limit at the end of which it should be formally opened for re-examination by all parties including the public.

Short Term Limit on Primary Control Equipment (IV.D)
      The covenant should commit 3M to operating the carbon adsorber at an efficiency of 95% whenever a coater is operating. Currently, this commitment only lasts for eighteen months.

Minor Issues
      Why does reporting take 60 days? Currently it is virtually instantaneous.

      We need a separate MOU on fees to be paid by 3M. Delete III.A.4

      All references to procedures need to be specific

      Products of combustion include ROC. Rule 74.15 limits substitute for AP 42 for NOx. (Attachment 1.B)

      Current graphic arts operations are not addressed

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


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