To:
Tom
Holloway
From:
Dave
Reeves
Vince
Hellwig
Date:
July
29,
2002
Re:
Imation
Enterprises
Corporation
 
Weatherford,
OK
Facility
1.
The
Imation
facility
located
in
Weatherford,
OK
was
recently
bought
by
Kodak
(
2002).

2.
Facility
location:
2000
E.
Frontage
Road,
NW/
4,
Section
10,
T12N,
R14W,
Custer
Co.

3.
The
Imation
facility
was
built
in
1967
and
was
part
of
3M
Corporation
manufacturing
data
storage
(
e.
g.,
hard
disk)
products.
Imation
was
spun
off
from
3M
in
1995
and
the
Weatherford
facility
now
has
two
primary
divisions:
color
technologies
and
data
storage.
The
Color
Technologies
Division
involves
graphic
arts
products
and
the
entire
division
(
including
the
building(
s),
process
equipment,
and
process
technology)
was
recently
purchased
by
Kodak
Polychrome
Graphics,
Ltd.
(
a
joint
venture
between
Eastman
Kodak
and
Sun
Chemical
Corporation).
The
Data
Storage
Division
is
owned
by
Imation
and
is
located
in
a
separate
building
with
separate
control
device(
s)
and
involves
magnetic
coatings
applied
to
polyester
film
via
a
web
coating
process
to
produce
flexible
media
used
in
diskettes.

4.
There
are
7
organic
materials
storage
tanks
on­
site
used
to
store
organic
solvents,
gasoline,
diesel
and
No.
2
fuel
oil.
The
storage
tanks
range
in
capacity
from
325
to
10,000
gallons.

5.
The
facility
is
located
70
miles
west
of
Oklahoma
City,
OK
at
an
elevation
of
1,670
feet
above
sea
level
in
an
area
characterized
by
gently
rolling
hilly
terrain.
The
discharge
stack
for
the
control
device
associated
with
the
magnetic
tape
coater
is
30
feet
high,
3.5
feet
in
diameter,
and
the
exit
gas
temperature
is
400oF
and
has
a
flowrate
of
30,000
cfm.

6.
Permit
VOC
limit
=
249
tons
per
year
and
a
maximum
hourly
emission
rate
=
836
lbs/
hr.

7.
The
nearest
Class
I
area
to
this
facility
is
the
Wichita
Mountains
Wildlife
Refuge
near
Lawton,
OK,
80
miles
to
the
south.
The
protracted
transport
distance
and
downwind
direction
of
the
facility
to
the
prevailing
winds
precludes
any
significant
impact
on
Class
I
areas.

8.
The
thermal
oxidizer
for
the
magnetic
tape
line
(
coater,
solvent
storage
tanks,
mix
equipment,
condenser
vents
in
solvent
recovery,
coating
operations,
and
waste
handling
devices)
has
a
control
efficiency
greater
than
the
required
95%.
(
last
performance
test
=
97%)

9.
There
are
no
chrome
compounds
used
at
the
facility.

10.
The
Data
Storage
Division
has
about
50
employees
and
is
located
in
the
back
(
or
south)
building.
The
facility
runs
24
hours
a
day,
five
days
a
week.
The
Data
Storage
Division
is
­
2­
currently
producing
media
for
50
million
diskettes
per
month
or
2.5
million
per
day.

11.
Data
Storage
Operations
­
The
general
production
process
involves
manufacturing
magnetic
tape
in
a
web
coating
process.
Metal
oxides
(
magnetic
particles)
are
mixed
with
binders
and
solvents
to
produce
a
magnetic
coating
which
is
then
applied
to
clear
polyester
film
(
substrate).
The
film
comes
from
Dupont
in
rolls
that
are
14.25
inches
wide.
The
film
(
web)
is
coated
single­
sided
using
an
extrusion
coater,
then
inverted
through
a
series
of
rollers
to
coat
the
other
side.
Typical
linespeeds
range
from
300
to
600
feet
per
minute.
Imation
uses
only
solventborne
coatings
for
their
data
storage
products.
After
the
coater,
the
coated
web
is
dried/
cured
in
an
indirect
steam
heated
oven
(
for
solvent
removal)
through
a
series
of
five
heating
zones.
The
oven
temperature
range
is
160
to
200

F
.
After
curing,
the
coated
web
is
slit
into
four
strips,
each
3.5
inches
wide.
Each
part
of
the
slit
film
is
rewound
onto
a
separate
roll
and
put
into
a
final
cure
room
for
three
days
at
120
to
130

F.
The
final
cure
allows
crosslinking
of
the
magnetic
material
on
the
film.
The
rolls
of
film
are
then
brought
into
the
final
packaging
room
where
the
diskette
media
(
called
"
cookies")
are
stamped
out
in
3.5
inch
diameter
circles.
The
cookies
are
stacked
in
bundles
of
1000,
and
then
12
stacks
are
placed
in
a
shipping
suitcase.
The
packaged
media
is
then
sent
to
a
sister
plant
in
North
Dakota
where
the
diskettes
are
assembled
into
a
final
product
(
i.
e.,
120
megabyte
diskettes).

All
of
the
data
storage
manufacturing
(
coating)
activities
are
considered
to
be
operating
in
a
permanent
total
enclosure
(
PTE).
The
coater
and
curing
oven
are
located
inside
an
enclosure
(
process
line)
within
an
enclosure
(
room).
The
coating
line
enclosure
is
fixedwall
construction
with
polycarbonate
walls
that
the
operators
can
see­
through
and
monitor
the
process
equipment.
The
enclosed
coater
and
curing
oven
are
maintained
under
negative
air
pressure
conditions.
The
VOC
emissions
from
the
coaters,
curing
ovens,
and
mix/
pump
rooms
are
manifolded
to
the
control
device
(
i.
e.,
thermal
oxidizer).

Other
coating­
related
equipment
is
housed
in
the
coating
mix
and
pump
room
areas.
The
data
storage
coatings
are
all
made
on­
site
using
precise
formulation
recipes.
The
coating
material
is
run
through
a
series
of
three
high­
shear,
high­
energy
mills
to
create
the
proper
particle
size
in
the
coating.
After
the
milling
process,
the
coating
has
approximately
45
percent
solids
content
and
solvent
is
added
to
the
material
to
achieve
a
final
coating
with
27
percent
solids.
Then
the
material
is
filtered
through
a
0.3
micron
filter
and
transferred
to
a
storage
drum.
Methyl
ethyl
ketone
(
MEK)
is
used
for
most
equipment
cleaning
applications.
Material
usage
of
all
coatings,
solvents,
and
coating
materials
(
e.
g.,
resins
and
binders)
is
tracked
on
an
individual
"
coating
batch"
basis.
All
solvent/
coating
materials
are
handled
and
stored
in
100­
gallon
stainless
steel
mix
containers
or
55­
gallon
drums.

12.
Data
Storage
Add­
On
Controls
­
Imation's
operations
are
required
to
have
a
permanent
total
enclosure
for
the
manufacturing
operations
to
comply
with
the
Subpart
EE.
Air
flow
monitoring
of
the
total
enclosure
is
done
via
differential
gauge
pressure
to
show
the
­
3­
enclosure
is
at
a
negative
pressure
with
respect
to
the
immediate
surrounding
environment.
All
18
doors
to
the
Data
Storage
manufacturing
area
also
have
contact
switches
with
electronic
interlocks
that
automatically
close
the
door
after
15
seconds;
the
actual
"
open"
time
for
each
door
is
monitored
and
tracked.
An
operator
alarm
goes
off
if
a
door
is
open
longer
than
3
minutes.

One
regenerative
thermal
oxidizer
(
RTO)
is
used
to
control
VOC
emissions
from
the
Data
Storage
coating
operations.
Solvent
emissions
from
coater
51W
and
the
associated
curing
ovens,
as
well
as
the
air
exhausts
from
the
coating
mix
and
pump
rooms
are
routed
to
the
RTO.
The
typical
air
velocity
through
the
unit
is
approximately
28,000
cubic
feet
per
minute
(
cfm).

For
the
Data
Storage
operations,
performance
testing
to
verify
destruction
efficiency
of
the
51W
RTO
was
conducted
in
August
1996.
The
test
results
documented
an
average
97
%
destruction
efficiency
based
on
an
average
of
three
1­
hour
tests
at
1400

F.
During
the
site
visit,
the
actual
temperature
was
above
1600

F.
Five
Type
K
thermocouples
are
used
to
monitor
the
incineration
temperature
as
part
of
the
continuous
parameter
monitoring
system.
The
carbon
adsorption
unit
was
not
being
utilized
during
the
site
visit.
No
significant
changes
were
identified
relative
to
the
RTOs
or
the
carbon
adorber
since
the
initial
testing
conducted
in
1996.

13.
VOC
Emissions.
Based
on
the
data
reviewed,
daily
VOC
emissions
are
typically
less
than
600
pounds
(
0.3
tons)
and
the
annual
VOC
365­
day
rolling
annual
emissions
ranged
from
76
to
90
tons
per
year
for
the
years
1997
through
2000,
demonstrating
compliance
with
the
annual
emissions
limit
of
249
tons
per
year.
Less
than
50%
of
the
total
VOC
emissions
for
the
facility
come
from
the
magnetic
tape
manufacturing
operations.

Annual
actual
emissions
reported
for
1997
through
2000
are
shown
in
the
following
table:

Imation
(
Total
Facility)
Actual
Emissions
Inventory
(
tons/
year)

Year
VOC
PM
SO2
NOx
CO
1997
79.128
1.842
.0555
18.322
10.834
1998
76.348
0.923
0.057
20.53
14.17
1999
86.739
1.099
0.067
25.27
20.171
2000
90.059
1.424
0.058
23.22
21.526
Based
on
the
data
reviewed
for
the
first
10.5
months
of
2001,
the
total
VOC
emissions
associated
with
magnetic
tape
manufacturing
operations
are
approximately
7
tons
per
year
(
tpy)
(
6.1
out
of
68.8
tons
cumulative
emissions
through
11/
14/
01).
The
predominant
solvents
comprising
the
VOC
emissions
are
MEK
(
50%),
toluene
(
35%),
xylene
(
5%),
­
4­
glycol
ethers
(
5%),
and
ethyl
benzene
(
5%).
(
NO
HAP
METALS)
