3M: Hutchinson, Minnesota

3M: Letter from Tom Zosel to David Gardiner

3M Environmental Technology PO Box 33331
and Services St. Paul, MN 57133-3331
612 778 6442

May 22, 1996
3M
Mr. David Gardiner
Assistant Administrator OPPE
U.S. Environmental Protection Agency
401 M Street Southwest
Washington, DC 20460

Dear David:

I believe the conference on Environmental Technology went extremely well and clearly highlighted the value of the Administration's initiative as a support for America's environmental technology industry. We at 3M appreciated the invitation that was extended to Mr. DeSimone. I know that he felt his participation was a very productive experience.

A portion of our discussions in the Regulatory Reinvention section focused on how new technology interfaces with reinvention and particularly with Project XL. While our focus has always been that the flexibility which we are seeking will enable us to use new technologies more efficiently, we have not been highlighting the technology innovations that are already proceeding at these sites. The following is a brief overview of how Project XL is promoting the use of new environmental technologies at the three 3M Project XL sites.

Camarillo, California

The Camarillo site will become a part of Imation as of July 1. Imation is the new company which 3M is forming to focus on the imaging and information technology businesses. This facility will be the flagship of Imation's operations.

The flexibility to quickly modify their existing equipment or to add new technologies will be of critical importance to Camarillo's future business success. The imaging and information business, particularly the production of computer data cartridges (Camarillo's specialty), requires constant change to meet the customers ever changing needs. This need for change will be even more critical as Imation moves into new technology driven markets.

There is one technology change and one technology innovation that is already planned for Camarillo. The technology change will be the incorporation of metal particle tape into the production operation. At the present time metal particle tape is manufactured in Japan. This technology change means that a product which is currently being manufactured offshore will now be manufactured in the United States. This is the initial step in moving new products and new technologies into the Camarillo facility.

Equipment modifications and the potential addition of new equipment will be required as this technology becomes an increasing portion of Camarillo's production operations.

Mr. David Gardiner
Page 2
May 22, 1996

The environmental technology innovation is the potential use of an extractive FTIR system to monitor the emissions from Camarillo's carbon adsorption system. FTIR is Fourier Transform InfraRed. It is a method to continuously monitor the emission of individual VOC's rather than measure the total amount of VOC without delineating the specific components. This will be the first time any plant has used this type of equipment as a continuous emission monitor. It is truly the application of cutting edge breakthrough technology. 3M's Environmental Laboratory staff has been working closely with the monitoring experts of the EPA operations at RTP on this monitoring technique for a number of years.

The flexibility which is afforded by Project XL will allow us to incorporate this technology without the time consuming process of developing a formal approval for the monitoring protocol which is being proposed. All involved, 3M, U.S. EPA, and the technology companies that are supplying the equipment, will gain immeasurably from the ability to test and hopefully utilize this innovative technology.

Hutchinson, Minnesota

Hutchinson represents a very unique challenge for Project XL. Shortly after 3M received approval for Project XL from U.S. EPA, our top management announced the formation of the new Imation company and that we would eventually be exiting the magnetic tape business. The Hutchinson plant at the time of this announcement was the largest manufacturing operation for magnetic tape in the United States.

3M's Chairman and CEO, Mr. DeSimone, also stated that 3M would try to exit this business and convert the Hutchinson plant to other products with a minimum of employment disruption. The goal was to have no involuntary layoffs. We estimated that this conversion to new technology would require a minimum of 20 PSD permits over the next two to three years. That would represent a daunting task for both the 3M environmental engineers and the permit engineers from the Minnesota Pollution Control Agency (MPCA).

However, with the appropriate flexibility built into the Project XL agreement, the conversion of the Hutchinson plant to new technologies will be accomplished much quicker, with less regulatory work from all concerned, and most important, meet the goal of minimum employment disruptions.

In that regard, 3M has already announced that three new pieces of production equipment will be added at Hutchinson. One unit will utilize volatile organic compound (VOC) coating but will have VOC emissions that are substantially below other production units at Hutchinson. The other two manufacturing units

Mr. David Gardiner
Page 3
May 22, 1996

that will be installed will utilize a new solventless technology for the production of pressure sensitive tapes. These are state-of-the-art environmental technology installations.

The flexibility that is afforded under Project XL will allow 3M Hutchinson to continue this conversion to new technologies and modification of existing equipment to new products and innovative technologies.

Bedford Park, Illinois

The 3M facility in Bedford Park has already converted some of its manufacturing capacity to solventless production technologies. At the present time there are discussions on the potential for additional innovative technologies at Bedford Park but no decision on that has been made at this point in time.

Summary

While 3M's Project XL has focused on regulatory flexibility, a fundamental purpose of that flexibility is to gain the ability to more quickly incorporate innovative environmental technologies into our operations. The facilities that have been chosen as initial Project XL sites are already responding and are beginning to see that regulatory flexibility is a critical element in getting these technologies on line and operational. This will demonstrate not only the environmental benefit of Project XL but the profound impact that it will have on the deployment of environmental technologies and the economic benefits that it will have for these facilities and for the plant communities.

If you or anyone on your staff has any questions or needs additional information, please contact me at your convenience.

Thomas W. Zosel
Manager, Environmental Initiatives

TWZ:cmr

c: A. J. Donelson, 3M St. Paul
Michael Driver, Patton Boggs
Fred Hansen, U.S. EPA
Timothy Newall, Whitehouse Office of Science and Technology Policy
David Rejeski, Whitehouse Office of Science and Technology Policy
D. A. Sonstegard, 3M St. Paul

3M: Hutchinson, Minnesota

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