*EPA
SUMMARY OF
THE IMATION
PROJECT
PROJECT XL?
SUPERIOR
ENVIRONMENTAL
PERFORMANCE
United States
Environmental Protection
Anpnru
Office of the
Administrator
[Mail
1S09]
EPA-100-F-00-005
February 2000
fhttp'//www ppa
Project XL:
Imation Corporation
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Project XL, which stands for "excellence and Leadership," is a national initiative that
tests innovative ways of achieving better and more cost-effective public health and
environmental protection. The information and lessons learned from Project XL are
being used to assist EPA in redesigning its current regulatory and policy-setting
approaches. Project XL encourages testing of cleaner, cheaper, and smarter ways to
attain environmental results superior to those achieved under current regulations and
policies, in conjunction with greater accountability to stakeholders. It is vital that each
project tests new ideas with the potential for wide application and broad environmental
benefits. As of December 1999, sixteen pilot experiments are being implemented and
thirty-five additional projects are in various stages of development.
Imation Corporation produces magnetic data-storage tapes, primarily for the computer
industry, at its plant in Camarillo, California. Magnetic tape manufacturing employs
high-technology processes and caters to a rapidly evolving worldwide industry. To
stay competitive in this fluid international environment, Imation must be able to make
changes to existing production processes or begin producing new advanced products
without delay. However, Clean Air Act regulations require manufacturers to obtain
approval for each prospective change to plant processes and/or new equipment
addition. This is typically done through a preconstruction review procedure and
revision of the plant's operating permit. Following these traditional procedures
impedes Imation's ability to respond rapidly to the marketplace, particularly since
Imation anticipates numerous changes over the next several years. Through Project
XL, EPA is employing a broader interpretation of existing preconstruction review and
permit rules to preapprove changes Imation anticipates making in the future. The
preapproval strategy is meant to satisfy the preconstruction review and permit revision
requirements that otherwise would apply, while allowing Imation to make changes
without delay. The Final Project Agreement, EPA's seventeenth XL project, was
signed on December 21, 1999.
The project provides the following environmental benefits:
• Imation will comply with emissions caps on volatile organic compound (VOC)
emissions, which produce smog, and other air pollutants. The VOC cap is below
the baseline level of current actual emissions. Emission reduction credits generated
through imposition of the VOC cap will in part be retired by Imation and in part
donated to Ventura County. Ventura County will sell the credits and use the
proceeds to fund clean air projects that would not have been funded otherwise.
• Imation equipment emitting VOCs will comply with the most stringent federal
emission reduction requirements of all those that apply at the plant, even though
many plant operations are subject to less rigorous requirements.
• VOC emissions will be tracked through a state-of-the-art continuous emissions
monitoring device, which is not otherwise required. This will provide the best
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available compliance information.
FLEXIBILITY
STAKEHOLDER
INVOLVEMENT
APPROACHES TO
BE TESTED
CONTACTS
Traditional case-by-case preconstruction review processes are meant to ensure that
plant changes (1) do not jeopardize attainment and maintenance of national ambient air
quality standards or (2) reasonably further progress toward attainment. In this
Imation experiment, the VOC cap will be established at a level specifically to serve
those functions, and individual preconstruction reviews will not be triggered. Also,
the changes anticipated by Imation will be described and preapproved in their
operating permit expanding the use of alternate operating scenarios. Although
alternate operating scenarios are already allowed under current permitting rules, they
commonly allow only precisely defined changes to existing equipment. The
innovation in this project is to use alternate operating scenarios to preapprove
classes of changes to existing equipment and additions of new equipment, thereby
avoiding the need to revise Imation's permit prior to such changes.
The project details and draft Final Project Agreement are products of an active
stakeholder group that consists of EPA, California Air Resources Board, Ventura
County Air Pollution Control District (APCD), and community representatives.
Several Ventura County organizations offered valuable input, including the
Environmental Coalition, the American Lung Association, and the Ventura County
Economic Development Association. An ongoing stakeholder group will participate in
evaluating the project, recommending changes to the project, assisting in brining out
community concerns, and maintaining a dialogue with Imation to ensure transparency
of project-related operations and continued superior environmental performance.
• 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?
• Will Imation experience decreased time to implement changes under this
experiment?
• Are permitting "transaction" costs reduced for the environmental agency and
Imation compared to the traditional system?
EPA Region:
EPA HQ:
Ventura County APCD:
David Albright
David Beck
Karl Krause
415-744-1627
919-541-5421
805-645-1420
More information about Project XL is available on the Internet at
FOR ELECTRONIC http://www.epa.gov/ProjectXL, or via Project XL's Information Line at
INFORMATION 202-260-5754
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