Nature of Relief Provided by the Project. The following are the main areas of flexibility that are being provided as part of this XL project. First, Imation Camarillo will not be subject to the VCAPCD’s major and minor New Source Review program for most facility modifications. This flexibility will allow Imation to quickly carry out changes in their equipment and processes in order to respond dynamically to market demands. Imation’s agreement to emission caps, control technology assessments, use of state-of-the-art control and monitoring equipment, and detailed monthly reports will ensure that these changes are carried out in a publicly transparent and environmentally protective manner. Relief from the District’s major and minor NSR program will be granted through the District Board’s adoption, and EPA’s approval, of a site-specific District rule which will revise the Ventura County portion of the California State Implementation Plan (SIP). The site-specific SIP revision is further described in Section I.E of this FPA. Second, Imation Camarillo will receive pre-approval for purposes of its title V permit for certain changes that would subject the facility to five New Source Performance Standards (NSPS), a Maximum Achievable Control Technology (MACT) standard, and several District regulations. Such advance approval is warranted in this case because of the general similarity of the various potentially applicable standards, the unique operating conditions at the Imation Camarillo facility, and the ability to reasonably anticipate these pre-approved changes. All of the federal and state standards addressed by Imation’s pre-approvals regulate coating operations which emit VOCs and HAPs, and the pre-approved operations will be identical or very similar to the existing coating operations at the facility. As for the operation of the facility, Imation maintains the areas where VOC and HAP-emitting coating operations are conducted under a condition of total enclosure (100 percent capture of all organic compounds). These total enclosures, which are vented to a highly-efficient solvent recovery unit, will allow Imation to conduct various types of coating and related activities in compliance with the VOC/HAP control standards of all relevant NSPS, MACT, and District standards. In addition, several continuous emissions monitoring systems (CEMS) are in place at the facility that will provide further assurance that existing and new operations at the facility are complying with all applicable standards. Third, sev...
