United States
                         Environmental Protection
                                 Office of the
February 2000
fhttp'//www ppa
Project XL:
Imation Corporation
                                                                                    s =  K ve'h-
 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.
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
  Are permitting "transaction" costs reduced for the environmental agency and
   Imation compared to the traditional system?
EPA Region:
Ventura County APCD:
David Albright
David Beck
Karl Krause
                        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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