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3M: Hutchinson, Minnesota

3M: Meeting Summary


Office Memorandum


DATE: August 1, 1996 (DRAFT)

TO: 3M Project XL File

FROM: Andy Ronchak

Project XL, Coordinator

PHONE: 296-3107

SUBJECT: Summary of July 30, 1996 meeting with 3M, EPA, MPCA, and the PPC

The following 30 people attended the meeting held at the Holiday Inn International Airport on July 30, 1996, from 9:30am to 5:30pm:

3M: (1)David Wefring - 3M XL Coordinator; (2)Mike Nash - 3M legal; (3)Patty Kirchoff - Plant Environmental Rep.; (4)Gary Garner - Corporate Envir. Rep.; (5)Cheri Kedrowski - Corporate Envir. Rep.; (6)Doug Ward - 3M VP; (7)Jim Bauman - Hutchinson Plant Manager; and (8)Theresa Hooper - 3M federal gov't. affairs.

EPA: (1)Marilou Martin - Reg. V XL coordinator; (2)Brian Barwick - Reg. V assist. XL coordinator; (3)Bill Wagner - Reg. V. ORC; (4)George Wyeth - OGC; (5)Alan Eckert OGC/AIR; (6)David Ullrich - Reg. V Deputy Admin.; (7)Jon Kessler - EPA XL Coordinator; (8)Jack Edwardson - OAQPS/NSR; (9) Gail Lacy - OAQPS/Air Toxics; (10)Mike Sewell - OAQPS/NSR

MPCA: (1)Andy Ronchak - MPCA XL Coordinator; (2)Ann Seba - MPCA legal; (3)Peggy Bartz - MPCA - AQ; (4)Lisa Thorvig - MPCA - Deputy Commissioner; (5)Dennis Becker - AQ Modeling; (6)Cynthia Hollerbach - Air Toxics; (7)Greg Berger - Haz Waste.

Pilot Project Committee (PPC) - MPCA stakeholder group: (1)Jon Bloomberg - PPC/Industry rep; (2)Carol Wiessner - PPC/Minnesota Center for environmental Advocacy; (3)Alfred Marcus - PPC/University of Minnesota; (4)Lee Paddock - PPC/MN Attorney General's Office; and (5)Brett Smith - PPC/North Star Chapter of Sierra Club.

ATTACHMENT: Agenda Item Summary of Issues and Resolutions

Meeting Agenda

Project XL - 3M Hutchinson

Meeting Date and Time: July 30, 1996 9:30am to 5:30pm

Conference Room: Holiday Inn International Airport, Bloomington, Minnesota Resolution

Agenda Items Resolution Resolution Who/by what date
1) Proposed 3M Modification 113a authority will be used by EPA. Will include a stipulation that 3M will go through a synthetic minor permit amendment if XL permit is not issued. EPA will write in a non-enforcement type manner. The MPCA will issue a similar letter to address state requirements.

a. Letter from MPCA

b. Letter from EPA

EPA & MPCA/1 wk - dft for review

EPA & MPCA/2wk-final

(general rule)

2) Title V Issues

a. permit term

b. public notice

c. records for regulatory analysis

d. certification

a. 3M will request reissuance and supply necessary information for MPCA to reissue at five year point

b. 30 day public notice

c. defer

d. 3M will certify annually

a. permit change

b. none needed

d. permit change

a. MPCA/before permit is issued

d. MPCA/before permit is issued

3) EMS

a. EPA approval of key parts

b. reg. analysis records

c. timeframe

a. add EPA to III.C.1. of permit, share EMS segments with stakeholders (reflect in FPA)

b. defer

c. defer

a. permit change, FPA change a. MPCA/before permit is issued and FPA is signed
4) EPCRA OK as 24 hr - with clarification not waiving EPCRA permit change to clarify not waving EPCRA MPCA/before permit is issued
5) Unilateral Withdrawal from FPA Grounds proposed in FPA OK. The grounds will track with grounds to revoke in permit permit change to make grounds in permit and FPA the same MPCA/before permit is issued

6) RCRA Issues

a. subpart cc

b. 180 day storage

a. Cover tanks and haz waste tanks; no surface impoundment's; maintenance of tanks; show .5 ton offset. 3M will review requirements in relation to haz. waste tanks and work with MPCA on permit and FPA language.

b. proposed language OK

a. permit change to include subpart aa, bb, and cc requirements in EMS. In FPA show offset upfront and in reg. analysis.

b. language proposed addresses this

a. 3M and MPCA/before permit is issued, and amend FPA

b. no change

7) Changes to Boilers Modification Modifications to existing or new combustion units -- 3M will comply with NSR and NSPS. 3M would commit to restrict PM10 emissions from process equip. from triggering NSR. The one boiler with the PSD limit was determined to be a problem in coming up with a solution. No resolution was reached. Deferred    

8) Superior Envir./Reg. Analysis

a. 10% issue

b. HAPs


a. We all recognize that we need to have superior environmental performance as a condition in the permit. We were not able to agree on what SEP is. MPCA believes that the current XL permit is SEP today and that the regulatory analysis will provide sufficient information to ensure that there is SEP in the future. EPA does not agree with the MPCA. We do not agree on how to address the issue of voluntary controls 3M has installed to date. We do not agree on how the regulatory analysis is done.

b. did not get to it

9) Reg. Analysis Frequency did not get to it    
10) Legal Mechanism did not get to it    
11) Review EPA Comments did not get to it    
12) Fill in time commitments did not get to it    


The following is an attempt by the MPCA to put down in permit and FPA language the what the MPCA thinks the attached counter proposal from EPA (Jon Kessler) means. Please note: Peggy Bartz from the MPCA was attempting to confirm this on August 7th, but was not able to contact Jon Kessler. There are additional issues to address and this is only intended to address the SEP issue and stakeholder issue, as outlined in the August 6th Kessler memo. Please note this language has not been reviewed by 3M.

Permit Change 1.

III. Environmental Management System.

A. Development, Implementation and Audit of Environmental Management System.

4. The permittee shall conduct an annual internal audit of the EMS each year, except in 1998, and 20001 and 2005. In 1998, and 20001 and 2005, the permittee shall submit to the MPCA by November 1 a summary of the results of an audit conducted by an independent third party auditor qualified to conduct an EMS audit. All audits shall address the EMS criteria in Attachment 3.

Permit Change 2

IV. Other Requirements.

B. Air Quality Regulatory Limitation Analysis. The permittee and the MPCA shall complete an air quality regulatory analysis report to compare the pollutant limits in section II.A.1, Tables 1 and 3 to state and federal regulatory requirements at the time of the analysis. The regulatory analysis report shall be completed on each of the following dates: November 1, 1998; November 1, 20001 and November 1, 2005. The regulatory analysis shall establish what the new allowable emissions based on maximum production capacity. In addition, the analysis shall establish what 90% of the the allowable emissions were for VOC and HAP emissions of each pollutant would be based on actual production data on a facility-wide basis under state and federal regulations at the time of the analysis. The regulatory analysis shall be performed for each unit for major emissions units, but units may be grouped for smaller emission units (e.g., tanks and mixers). The permittee shall maintain records necessary to conduct the regulatory analysis. At the time each of these analyses are completed, the MPCA will decide whether it needs to amend this permit to keep the pollutant limits at or below state and federal regulatory requirements.

Permit Change 3

G. Permit Revocation. [Ann Scha] In addition to the grounds for permit revocation in Minn. Stat. §114C.12, subd. 5, the termination of the Final Project Agreement for the facility dated August , 1996, or the permittee' s unwillingness or inability to lower air polutant emission caps for the facility to a level at or below the level required by section IV.B, constitute justification for the MPCA to revoke this permit.



Criteria for determining Superior Environmental Performance in the FPA.

1) an 90% of allowable emissions compared to actual emissions;

2) units of production compared to units of pollution;

3) 1995 baseline emissions compare to actual emissions;

4) amount of waste (solid and hazardous) reduced or recycled;

5) amount and type of pollution prevention;

6) stakeholder and public participation in the process;

7) permit limits (including risk analysis limits) compared to actual emissions;

8) an evaluation of the affect an Environmental Management System has in obtaining continuous environmental improvement; and

9) an evaluation of 3M, MPCA, and EPA resources saved due to the pilot.


Stakeholder Participation during Implementation Phase.

3M, MPCA, and EPA will share and receive comments from stakeholders on: 1) EMS sections submitted to the MPCA; 2) pollution prevention related information submitted; 3) the regulatory analysis results; and 4) the superior environmental performance evaluation.

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