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3M: Hutchinson, Minnesota
3M: Position on Superior Environmental Performance
What is "Superior Environmental Performance"?
3M's Perspective
There has been much discussion over the definition of "Superior Environmental Performance" relative to Project XL. From 3M's perspective, we feel we have already demonstrated "Superior Environmental Performance" both as a corporation and at the Hutchinson facility. Furthermore, not only have we demonstrated environmental excellence and leadership in the past, but we are now well positioned to continue our tradition of environmental excellence well into the future. We believe our participation in Project XL is part of that demonstration. With our experiment at Hutchinson, we hope to help government develop common sense ways of achieving superior environmental performance which is simply performance (measured in a number of different ways) which is better than required under existing regulation. Our Hutchinson facility has already demonstrated "superior environmental performance" under the existing regulatory structure. Under this experimental pilot, we believe the Hutchinson XL Permit will facilitate the development of new ways to continue and perhaps surpass the "superior environmental performance" of the past using common sense alternatives to the existing laws and regulations.
In short, (and as described in more detail below) the Hutchinson XL permit demonstrates superior environmental performance in the following ways:
| Under Project XL | Current Requirements |
|---|---|
| 4500 ton per year VOC cap | 32,903 tons per year allowed |
| 3000 ton per year HAP cap | No Requirement |
| HAP assessment form chronic risk | No Requirement |
| HAP assessment for acute risk | No Requirement |
| ISO 14001 Environmental Management System | Command and Control Regulations |
| Third Party Audit for EMS | No Requirement |
| Local Stakeholder Involvement | No Requirement |
Past Superior Environmental Performance at 3M - 3M has a long history of superior environmental performance. More than 30 years ago, 3M recognized the need to address potential environmental issues. 3M's formal environmental strategy, goals and achievements span two decades. As early as 1975, 3M's Board of Directors had established an environmental policy. The policy led to the development of the now well-known 3P (Pollution Prevention Pays) program. Since 1975, 3M has developed more than 4100 pollution prevention projects, eliminating 1.3 billion pounds of pollution. Since 1990, the company has invested $175 million worldwide on pollution control equipment to reduce air emissions. We recently met our most aggressive environmental goal to date by reducing our global air emissions by more that 70 percent. We have established a number of corporate environmental policies like our Air Emissions Reduction Program (voluntary reduction of air emissions), Underground Storage Tanks Program (remove underground storage tanks prior to deadlines), PCB and Ozone-depleting chemical phaseouts to name a few. These innovative environmental programs have led to numerous US and international environmental awards over the years. In fact, earlier this year, 3M received the 1996 Presidential Award for Sustainable Development for its 3P program. Thus, we believe that anyone who takes the time to get to know our environmental record would agree we have clearly demonstrated " superior environmental performance" as a company in the past.
Future Superior Environmental Performance at 3M - We are now accelerating a transition from the era of compliance toward an era of sustainable development. Our focus is therefore sharpening on products and processes that meet customer need and respect the ability of future generations to meet their own needs. One example of this accelerated program is a new corporate goal to reduce all releases to air, water and land 90 percent and generation of waste by 50 percent by the year 2000 based on 1990 levels. Ultimately, our goal is to approach zero releases. Given these aggressive goals for the future, it is clear that 3M has every intention of continuing its long tradition of demonstrated superior environmental performance. We have every incentive to do so.
Past Superior Environmental Performance at 3M Hutchinson - Over the last seven years, 3M Hutchinson has reduced its emissions of VOCs from 18,453 tons per year to 2,307 tons per year. These reductions in emissions were accomplished primarily on a voluntary basis due to 3M corporate waste minimization goals and air emissions reduction policies. In addition, these emissions reductions occurred while production at the site increased by 67%. Since 1990, the magnetic tape plant has reduced waste from an average of 25 pounds per hundred pounds of total output to 7 pounds per hundred pounds of total output. Likewise, the Adhesive Tape plant has reduced the amount of waste being sent to the local landfill by 21 percent. This is clearly superior environmental performance given the fact that these reductions were largely made on a voluntary basis driven by corporate policy and culture rather that by regulatory requirements.
Current actual emissions of VOC's would be 17,181 tons per year if 3M Hutchinson did not operate its voluntary pollution control equipment. No company should ever be penalized for making voluntary reductions. Otherwise, every incentive is given for a facility like 3M Hutchinson to shut down all the voluntary control equipment and re-apply to participate in Project XL. At that point, 3M could propose to demonstrate "superior environmental performance" by reducing the VOC emissions down to 2300 tons per year within one day. This would be ridiculous, but it does illustrate the point that we have already demonstrated superior environmental performance and should be given credit for this exemplary performance. We should not be penalized through the regulatory assessment process for implementing this aggressive and forward looking program. To do so would put companies like 3M and other XL candidates at a competitive disadvantage for demonstrating environmental leadership and will reinforce the view that companies should not perform beyond what the regulations would require because to do so will only lead to the agency demanding further reductions. Evidence that 3M Hutchinson will continue to reduce emissions and will continue to implement its proactive pollution prevention program is demonstrated by a recent new product introduction. In November 1995, 3M announced that it would be discontinuing its production of blank videotape cassettes. 3M also announced at the time that we would be re-tooling the site for future production of different products, rather than closing down the North Building. As part of the re-tooling program, 3M will be installing three new pressure sensitive tape and label coating lines. 3M recently received a "synthetic minor" modification PSD permit for the project. To obtain a permit that limits the total emissions increase for three new coaters to such a low level was possible due to the innovative control technologies and processes 3M will be utilizing.
For the first coating line, which is a typical solvent based coating line, 3M will be installing emission control equipment that goes beyond the compliance requirements of existing regulations. Specifically, 3M will install thermal oxidation with permanent total enclosures that we expect will result in a minimum overall control efficiency of 96 percent. The remaining two coating lines to be installed will be utilizing a reactive coating technology in which essentially all the organic raw materials used are locked up on the web as part of the product, rather than being emitted to atmosphere or requiring the use of energy consuming emission control equipment. We believe this project is a great example of how 3M implements pollution prevention to further its goals to reduce emissions. We will continue to take this approach under Project XL.
Future Superior Environmental Performance at 3M Hutchinson - The Project XL permit will ensure that 3M Hutchinson continues to demonstrate superior environmental performance in the area of air emissions. In addition, our hope is this new innovative permit will allow the facility to experiment with new methods to perform even better than has in the past.
The Hutchinson Project XL permit establishes a cap of 4,500 tons per year of VOCS. This cap on VOC's represents future superior environmental performance for several reasons:
_ Allowable VOC emissions are reduced by 86%. (The existing capacity to emit as allowed by current permits is 32,903 tons per year vs. Project XL allowable emissions of 4,500 tons per year.) We believe that this level of performance is truly superior.
_ The VOC cap has actually been set approximately 15 percent below the emissions level associated with application of New Source Performance Standards (NSPS) to all existing thirteen coaters at the facility. Given that NSPS currently applies to only three of the coaters at the site, the emissions cap is extremely conservative.
_ As production at the facility increases, this cap will require additional VOC control measures or pollution prevention activities.
In addition to a cap of 4,500 tons per year, 3M will demonstrate continued excellence in the area of air emissions through several requirements set forth in the permit. One such requirement is the enforceable commitment to 3M's Air Emissions Reductions Program policy whereby 3M agrees to install best available control technology on sources of VOC emissions greater than 100 tons per year and to control all new sources which emit greater than 40 tons per year. Thus, new sources going into the facility will be required to be controlled in accordance with our long standing policy. The 3M Hutchinson Environmental Management System will describe 3M's methodology for determining appropriate control options.
In addition to the example provided earlier regarding three new pressure sensitive tape coaters at the site, evidence of how 3M currently approaches and will continue to approach the issue of control of new sources is provided by 3M's plan to convert an existing magnetic media line to a pharmaceutical coating operation. Because the current solvent recovery pollution control device is not compatible with the solvents used in the pharmaceutical process, a new thermal oxidizer will be installed to handle these new emissions. The coating process will be totally enclosed, and overall control efficiency is expected to be a minimum of 95%. This procedure complies with 3M's internal policy, which is now required as a part of the Project XL permit. This example as well as the previous example of installing low-solvent content products demonstrates quite clearly that 3M has every intention of continuing its program of improving the environmental performance of its products and processes.
In addition to the VOC cap and the enforceable commitment to our internal policy, we believe the HAP cap and associated risk assessment process represents future superior environmental performance. The HAP cap is set at 3000 tons per year. The MACT standard for magnetic media will apply to the plant in late 1997 but continued production of magnetic media will be phased out of the plant over the next few years. The MACT standard for pressure sensitive tape and labels is not expected to be effective until 2003. Thus, the HAP cap represents superior environmental performance in that it serves as an enforceable commitment long before any regulation would mandate this requirement.
In addition to the HAP cap, the MPCA has conducted (both from an acute and chronic perspective) an air toxics risk assessment for emissions at the cap level and is satisfied that there is no unacceptable risk. 3M has also committed to providing information to the Minnesota Pollution Control Agency so that continuous air toxics risk assessments can be performed by the MPCA. Additionally, 3M is committing to certain operating scenarios to insure that there is no unacceptable risk from an acute perspective. These assessments have occurred years in advance of any residual risk analyses that will take place under the CAA requirements, and the assessments will address the issue of new chemicals being emitted as the result of formulation changes. These actions are a significant commitment on 3M's part. EPA has indicated that it will not endorse any particular risk methodology at this time. Similarly, 3M has not endorsed this methodology. However, 3M agreed to try this approach following lengthy and detailed discussions with the MPCA as part of this XL experiment. These actions clearly show that on the HAP issue, the 3M Hutchinson experiment is clearly superior to what is required now and what will be required for the next 8-10 years.
The demonstration of superior environmental performance does not stop here. The 3M Hutchinson permit also includes a provision that requires a periodic regulatory assessment of the cap and actual emissions versus allowable emissions under command-and-control regulations. This assessment will be performed twice during the first five years of the permit and-could result in a decrease in the cap levels. This assessment will be used to measure the success of Project XL in terms of on-going environmental performance. These assessments in conjunction with increased public awareness through the stakeholder meetings, public access to emissions data, and third party audits of the facility EMS will serve to further 3M's commitment to continued superior environmental performance.
In summary, 3M has been working through the permit provisions with the MPCA, a Project XL participant itself, to demonstrate that as a company and as plant, we have committed ourselves to superior environmental performance. The Hutchinson XL permit is structured with sufficient checks and balances to ensure that superior environmental performance will continue to be the case. 3M's history shows that we are committed to the policies embodied in the XL permit. The Project XL experiment at Hutchinson is one built on history, experience and trust. We need to give it a try.