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Letter from Tom Zosel to EPA Region 9

February 16, 1996

Mr. Daniel Reich
Mr. Gerardo Rios
U.S. Environmental Protection Agency Region IX
75 Hawthorne Street
San Francisco, CA 94105-3901

Dear Dan and Gerardo:

I wanted to sincerely thank you for taking the time and energy to meet with the Ventura County APCD and to meet with us and tour our Project XL facility in Camarillo. I hope you could sense from the technical expertise and enthusiasm of the plant personnel that the commitment to environmental excellence is totally integrated into the entire operation.

While we have much to complete on Project XL, I sincerely appreciate your strong commitment to try to move this project forward. You had asked for various materials which I have attached to this letter. But my primary purpose in writing it is to convey what we believe to be the vision of Project XL and how it can be used to establish an entirely new way of approaching environmental challenges as stated by President Clinton.

Let me start out with a few facts about 3M Camarillo. This facility is the best controlled coating plant in the world! 3M is probably the largest coating company in the world and we know of no other facility that even comes close to the levels of control achieved by the Camarillo facility. As an example, in the last three years, the plant has brought no MEK or Toluene onto the site. It has been totally reusing the material it has for three years. That clearly demonstrates that virtually no emissions of MEK or Toluene are escaping the facility. This was also documented in our last compliance test in which only THF was detected in our exhaust stream and then only in the very low parts per million range.

This high level of control is achieved by treating the entire plant as a total enclosure. The emissions from every activity that occurs within that building are captured through an intricate air reuse system and are eventually conveyed to the solvent recovery system. The levels of control which we report are 98+ percent.

In addition, this new solvent recovery system which was installed in 1992, uses nitrogen desorption rather than steam. This was the first one of this type installed in the United States. It not only increased our efficiency, but totally eliminated the wastewater problems that are associated with steam desorption of carbon. Steam desorption is utilized in just about every other carbon adsorption system within the United States.

As could be seen from the information that was presented by Bob Michels at our meeting, the plant has also substantially reduced its water usage, solid waste generation, and hazardous waste generation. I would challenge anyone to disagree with the statement that this facility has achieved superior environmental performance.

As a point of reference, in the 1980's this facility emitted over 500 tons of VOC's, yet was in compliance with all of the existing environmental regulations. While new regulations have required emission reductions from those levels, this facility, if it was operating at production capacity and just meeting the regulatory limitations, would be allowed to emit over 300 tons today.

Our goal under Project XL is to set out a performance based emission limitation of 150 tons per year which we will verify through a state-of-the-art air emission tracking system. We would then have the flexibility to make whatever changes/modifications or additions to the facility as long as our emissions remained below that absolute cap.

I must also strongly emphasize that just because we have an emission limitation at that level there is absolutely no intention of reaching that level unless there is significant increases in business and expansion at the Camarillo plant. However, it is also an absolute business imperative that we do not give up potential production capacity through voluntarily accepted emission limitations.

Looking at it from a purely regulatory perspective, that facility has potentially put itself in a competitive disadvantage and substantially reduced its growth potential by being a good environmental citizen. It has returned close to 150 tons of emissions to the county for air quality improvement and has sold 78 tons of credits to Proctor and Gamble to accommodate an expansion that created over 250 new jobs in Ventura County. Since 3M has a commitment not to sell emission credits for profit, the proceeds from that sale ($1.5 million) were donated to Ventura County as an air quality improvement fund. It is important to note that this fund has contributed to projects that have reduced a comparable amount of emissions in Ventura County.

If this facility thought only of its growth potential and not its environmental responsibility, it would now have over 230 tons of emission in the bank and could be emitting at a rate of well over 100 tons today, over 300 tons if it were at historical production levels, and be in compliance with all applicable regulations.

It is unfortunate that the current regulatory system makes it easy for those facilities operating on the edge of compliance to modify or expand, yet it is exceedingly difficult for those facilities that are operating at a fraction of the regulatory limitations to expand or modify.

Any new environmental paradigm must reward those which have achieved superior environmental performance, not penalize them.

You had also raised the issue of air toxics and how we would guarantee into the future that this would not become a problem. That is an issue which has previously been discussed at our stakeholder meetings. Although at the present time our only emission is THF which is not an air toxic, we intend on reporting the individual compounds which are emitted in the future and including a requirement in our covenant that these emissions will never exceed a one in a million risk as calculated by the existing California requirements. It appeared that this was well accepted by the stakeholders, however, you are more than welcome to re-ask them that question at the next meeting.

I would also like to emphasize that our Project XL Proposal includes a commitment to make our emission information more publicly accessible. We will include this data on 3M's Internet Homepage (innovation@mmm.com) so that anyone will have access to it. In addition, the Stakeholder Committee will determine other methods of reporting to make the information available to those in the community who do not have electronic capabilities. Our eventual goal of Project XL is to send no paper reports to any environmental agency. We would put all of this information on internet and make it publicly available.

It is also critical to understand that one of the important, if not the most important facet of Camarillo's Project XL proposal, was to generate Emission Reduction Credits and utilize those credits for community benefit. The discussion on options as to how these credits should appropriately be utilized has been a focal point of our Stakeholder Committee meetings. These ERC's are the result of the emission reductions that were achieved by the installation of the current state-of-the-art emission control system and will be made enforceable by the establishment of the Project XL emission limitations. While the Stakeholder Committee has not recommended specific actions, it is their current thinking that a portion of the reductions would be donated back to the agency for air quality improvements. The remaining amount would be donated to an entity in Ventura County that would use these credits for economic development, essentially bringing new jobs into Ventura County. As these credits are then sold, the proceeds would be donated to community projects that would improve air quality.

This proposed system would create some exciting opportunities for Ventura County. At the present time, economic development organizations are hamstrung by having to tell prospective companies that they will need to find ERC's on their own. Under the system which 3M would hope to facilitate, the economic development organizations would have total control over these ERC's and consequently would have a much easier time attracting new businesses to Ventura County. This is a system which does not exist anywhere else in the United States.

These facets of our Project XL are in a way the most important benefits of this project for the local community. Again, it must be emphasized that this is the current thinking as reflected by our Stakeholder Committee discussions. If there are other innovative ideas which surface from our Stakeholder Committee which they believe will have an even greater benefit for Ventura County, then we will try to facilitate the incorporation of those innovative ideas into the project.

While this letter may have gotten a little long, I wanted to make sure that our view of all of the benefits of Project XL were fully put forth. It would appear to 3M, and I believe that this has been reflected in our Stakeholder discussions, that this project as we have outlined it clearly represents a win/win situation for Ventura County, 3M, U.S. EPA, and the environment.

As you had requested at our meeting, I have enclosed the following.
1. A first draft of the covenant which we see as the implementing mechanism for Project XL. Our objective is to try to keep this document to 10-15 pages and to make it understandable to the community.

2. A draft of the overview of the Environmental Management System. The total documentation of this system with all policies, procedures, manuals, training guides, operating procedures, etc., will probably fill four or five file boxes. That full documentation will be available for review in the near future.

3. A copy of the 3M Challenge '95 Guidebook which sets forth the pollution prevention metric which we have been using within 3M since 1990. On a corporate basis, the use of this metric has demonstrated that 3M has reduced its generation of waste over 30 percent in the last five years.

4. A copy of the legal notice announcing Camarillo's participation in Project XL and asking for input. It is important to note that we have received no inquiries at any of 3M's facilities as a result of this notice. As a result, we will be exploring other means such as radio announcements and advertisements when we make the announcements for our public meetings, which we intend on having once all of the facets of our project are better defined.

5. A copy of a recent letter which I have received from David Gardiner, emphasizing U.S. EPA's commitment to maintain the tight time schedule and reiterating the concept that the project proponents have the "authority and responsibility" for developing this project.

I would again like to thank each of you and Kerby Zozula of the Ventura County APCD, for all of the time and energy which you have put forth on this project. It is extremely important to us and I believe it is extremely important to the future of environmental policy in the United States.

Thomas W. Zosel
Manager, Environmental Initiatives

TWZ:cmr

Enclosures

c: Richard Baldwin, Ventura County APCD/w Att Jon Kessler, U.S. EPA Washington
Kerby Zozula, Ventura County APCD/wAtt Chris Knopes, U.S. EPA Washington
Maggie Kildee, Ventura County Supervisor Charles Byrnes, 3M Camarillo
Val Siebel, Cal/EPA Bob Michels, 3M Camarillo
Jim Strock, Cal/EPA Sara Ethier, 3M St. Paul
Felicia Marcus, U.S. EPA Region IX Dawn Krueger, 3M St. Paul
Linda Powell, U.S. EPA Region IX Dan Knuth, 3M St. Paul
Mary Ann Froelich, U.S. EPA Washington Mike Nash, 3M St. Paul
David Gardiner, U.S. EPA Washington Dave Sonstegard, 3M St. Paul
Fred Hanson, U.S. EPA Washington

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