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3M: Hutchinson, Minnesota
3M: Memo from Jon Kessler to Tom Zosel and Andrew Ronchak
UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY
WASHINGTON, D.C. 20460
OFFICE OF POLICY,
PLANNING AND EVALUATION
MEMORANDUM
Subject: Proposed Averaging System for Magnetic Tape MACT
From: Jon Kessler, Director
Emerging Sectors and Strategies Division
(for the 3M-Hutchinson XL Team)
To: Tom Zosel, 3M
Andy Ronchak, MPCA
Date: October 18, 1996 At our meeting in Washington on Oct. 10, we committed to provide you with the attached write-up, prepared by EPA's Office of Air and Radiation, of our proposed HAP averaging system for compliance with the magnetic tape MACT.
Based on the emission figures you previously presented, we believe that this proposal gives you the flexibility that you requested to use your beyond-compliance mag tape coatings controls in lieu of controls on compounding equipment. Tom, you will see that we have removed the "compliance margin" factor from the proposal in light of the points you made during the October 10 meeting.
Although our October 10 discussion suggests that we are in agreement on these points, I look forward to confirmation of that or to your additional thoughts on our call next Wednesday. Assuming we can agree on this outline of the magnetic tape averaging system, the next step would be to develop the necessary FPA and permit language, a point on which we are more than happy to take the lead.
MAG TAPE AVERAGING PROPOSAL
10/18/96
Outline of proposal
- A separate averaging system for HAPs would be established as an alternative means of compliance with the magnetic tape MACT standard. This averaging system would cover operations subject to that standard.
- HAP credits would be generated by levels of control superior to the legal limits in the magnetic tape MACT standard.
- In light of information provided by 3M, there would not be a compliance margin adjustment to the legal limit for purposes of calculating credits.
- A 10 percent discount factor would be applied to the credits generated by the coating control levels in excess of the regulatory requirements.
- Credit generated within the magnetic tape averaging system could not be used to offset undercontrol of operations not subject to the magnetic tape MACT standard.
- The rest of the plant would be governed by the more general provisions of the comparable actions test.
- Once the magnetic tape MACT is no longer applicable to the plant, the entire plant would be governed by the more general provisions of the comparable actions test.
Legal limits in magnetic tape MACT standard
In the magnetic tape MACT standard as promulgated, the legal limit for coating operations varies depending upon whether the source chooses to comply by averaging coating operations with storage tanks. The regulatory percent reduction requirement is 95 percent when the sources does not average at all. However, the required control level for coating operations is 97% if a source chooses to average coating operations with up to 10 storage tanks. Our understanding (based on emission figures cited by 3M in our September 25 conference call) is that even if the legal limit under the mag tape standard is 97 percent, 3M would still earn sufficient credits to offset excess emissions from compounding operations.
Rationale for separate mag tape averaging system
Because of 3M's stated intention to phase out of mag tape production, compliance with the mag tape NESHAP could require 3M to control operations that may be shut down or significantly modified a short time later. For such operations, controls may not be reasonable. This is an unusual, site-specific problem.
As previously discussed, EPA believes that past voluntary controls generally should not be included in assessing whether an XL project will achieve the actual emission reductions that would be achieved by otherwise applicable EPA regulations. Given the special circumstances in this case, EPA is willing to make an exception for the mag tape portion of the XL project for purposes of compliance with the mag tape NESHAP.