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3M: Hutchinson, Minnesota

3M: Memo from Jon Kessler to Tom Zosel and Andrew Ronchak




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.


Outline of proposal

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.

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