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Note from Ventura County to EPA on Project Completion - June 2009

Hi Joseph,
Here is some information on Imation for you to consider:
The initial Part 70 has been reissued.  The new term is February 1, 2006 to January 31, 2011.  As you may know, VCAPCD Rule 37 implements Project XL and the reissued permit is a "stand alone" document with no reference to Project XL or any outside project agreements.
Imation has utilized the flexibility offered by the permit, but only for some minor things such as mills and mixers that are in the PTE's (enclosures).  There have been no major changes such as new product lines, tape solvents, or new products that trigger "new" requirements.
As for your questions:
1) Will the preapproval approach to accommodating changes at a plant produce environmental compliance better than the traditional case-by-case review of changes? Are enforcement officials able to follow changes and determine compliance as easily?

In our case, the pre-approval resulted in a significant amount of voluntary emission reductions, a reduced PTE, and ERCs donated to the District.  The project looks like it got a lot more emission reductions than what would be achieved by traditional permitting of changes to date.  As for following changes, the permit that resulted from Project XL is very complicated.  As Imation people and VCAPCD people change, I am concerned that the permit is way too complicated to produce all of its desired results.
2) Will Imation experience decreased time to implement changes under this experiment?
The permit as designed has and will decrease Imation’s time to implement changes.
3) Are permitting “transaction” costs reduced for the environmental agency and Imation compared to the traditional system?

This is a tough one to gauge.  We haven’t had any formal tracking.  However, we do have a MOU outside of the permit that allows us to recover review costs.
In summary, we have not done a formal review, but we feel that the flexible permit is working.  The actual flexibility allowed is much more than the actual flexibility that they need, resulting in an overly complicated permit.  I am concerned that as new staff on both ends try to comply with and enforce the permit, a lot will be “lost”.
Hope this helps.  Call me if you have any questions or want to discuss in more detail.
Kerby Z.
Kerby E. Zozula
Supervising Air Quality Engineer
Ventura County APCD
669 County Square Drive
Ventura, CA  93003
Phone = (805)645-1421   
Fax = (805)645-1444
Email = kerby@vcapcd.org

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