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Pilot Flexible Air Permit Profile Source: Imation Corporation
The Oklahoma Department of Environmental Quality (ODEQ)
and EPA worked with Imation to develop a flexible air permit
that enables the company to make operational changes in an efficient manner.
By increasing the plant’s
ability to respond to market opportunities and to support
continual improvement activities, the flexible permit has
enabled Imation to rapidly respond to new customer needs
and to utilize timely production strategies. The flexible permit ensures
that all applicable regulatory requirements are addressed and creates incentives
for pollution prevention.
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Alternative Operating Scenarios (AOS) and Advanced Approvals |
Approvals to make a range of operational changes within several categories, such as modifications to or construction of new coating equipment and chemical storage tanks. Approvals for raw material changes, including streamlined determinations under Oklahoma’s State Air Toxics Program. |
Approved Replicable |
A replicable procedure was developed to enable streamlined review and approval of new chemicals in a manner that addresses State Air Toxics requirements. |
Plantwide emissions caps |
Plant-wide Potential-to-emit (PTE) limit established for VOC emissions (249 tons/year). |
Pollution prevention (P2) |
P2 Program and reporting requirements included in the permit. |
Implementation logs |
Log of AOS changes maintained at the plant. |
Environmental Benefits and Pollution Prevention
- Reduced allowable and actual air emissions. Imation has a 15 to 20 year history of commitment to pollution prevention (P2) – in part due to its association with 3M, a company with a very active pollution prevention program. Imation reported that the Weatherford plant has reduced air emissions by over 87% since 1988, and the amount of solid waste generated by the facility has declined by more than 75% since 1990. Imation’s Weatherford facility was one of the first three plants in the U.S. to participate in EPA’s Pollution Prevention in Permitting Program (P4).
- Easier P2 implementation. Over a period of ten years, the facility reduced both its air emissions and solid waste output by more than seventy-five percent. ODEQ representatives indicated that they believe that the design of the permit encourages pollution prevention, because the company feels that it has more flexibility or maneuverability by maintaining an emissions level significantly below the established cap. The alternative operating scenarios allow for reduced regulatory friction (uncertainty or time delay) associated with making operational or management changes in production.
Economic Competitiveness Benefits
- Agile manufacturing. Imation reports that the flexible permit has allowed the Weatherford facility to proceed with operational change in a manner that rapidly responded to customer needs and market demand. Since Imation ships much of its finished product directly to customers from the plant, the company pursues “just-in-time” production strategies to keep inventory and associated overhead costs low. Imation representatives indicated that the permit’s flexibility provisions supported such market responsiveness by allowing the plant to quickly shift between alternative operating scenarios.
Monitoring and Enforceability
- Replicable monitoring and routine reporting. Imation measures all VOC emissions, including fugitive emissions, using the mass balance monitoring approach. Any additional reporting and monitoring required under the permit assures enforceability and results in additional data availability for both the permitting authority and the public.
- Increased ease of inspection. Inspections for ODEQ under the flexible permit are easier due to the reduction in the number of unit-specific emissions limits.
Government Efficiency
- Paperwork and backlog reduction. ODEQ representatives reported that overall, they believe that “the flexible permit is much less expensive in time and manpower to implement.” They attribute this to the savings associated with a reduced number of case-by-case permitting actions and permit modifications required during the permit term.
Public Response
- Public support. After the draft permit was completed, ODEQ provided thirty days for public review of the draft permit. A notice of the public review period was posted in the Weatherford newspaper on March 29, 1998. Copies of the Imation draft permit were made available to the public at the local library and ODEQ offices. A public hearing was not requested. However, Imation and ODEQ representatives deemed a public meeting necessary at the end of the public review period helpful to properly explain the innovative nature of the flexible permit.
- No complaints. ODEQ representatives reported that no public comments were received during the permit development process. There were no comments from the public during the public comment meeting.
For More Information
- EPA Pilot Individual Flexible Permit Review Report
- Pilot Permit
- Pollution Prevention in Permitting Program (P4) – Lessons Learned and Next Steps. John F. Metzger, P.E. Imation Enterprises Corp. Presented: Air & Waste Management Association, June 17, 1998, San Diego
- EPA Pilot Flexible Permitting Evaluation Report