3M: Hutchinson, Minnesota

3M: Letter from Pilot Project Committee to EPA Administrator Carol Browner

September 19, 1996

Ms. Carol Browner
Administrator, USEPA
401 M Street SW
Mail Code A-100
Washington, DC 20460

Dear Ms. Browner,

We write this letter to you, as the Administrator in charge of decision making at the Agency, because we believe that once all levels of management fully understand the many ways in which the 3M Hutchinson Project XL permit can provide for superior environmental performance, the Agency will be able to move forward to the implementation phase in a unified manner.

Statements have been made by EPA (Project XL) staff, that the 3M Hutchinson Project XL agreement does not guarantee Superior Environmental Performance. It is true the permit, as public noticed, does not have all the prescriptive up-front guarantees that EPA is asking for to insure that 3M will meet the Agency's definition of Superior Environmental Performance" However, we are convinced this permit provides for significant overall superior environmental performance and contains a number of innovative features that should help us learn more about ways to improve environmental protection in this country. In particular the 3M Hutchinson Project XL agreement includes the following notable features:

1) a guarantee that ensures 3M's performance is well beyond what current regulations require or are anticipated to require in the five year term of the permit;

2) significant local and statewide stakeholder involvement in the permit development resulting in consensus to move to implementation;

3) a guarantee of continued involvement through evaluation and feedback from stakeholders during the implementation phase;

4) a greatly streamlined permit (20 permits @ ~300 pages into one ten page multi-media permit) which Minnesota stakeholders believe to be much more understandable to those impacted by the facility - the general public;

5) reporting of daily emissions in a user friendly graphical format on the internet;

6) using a health risk model to ensure protection of human health from the release of toxic emissions;

7) a commitment to shift environmental resource savings under the streamlined Project XL approach to innovative pollution prevention or emission reduction projects and to report these results;

8) testing of a detailed Environmental Management System for the facility that minimizes or eliminates overlap between records, reports or procedures required by regulations and those required in operating the facility, that makes it easier for plant management and staff to identify and understand the facility's requirements for environmental performance set by both government regulations and corporate policy which includes ambitious goals for future environmental performance including pollution prevention; and

9) unprecedented operational flexibility for increased global competitiveness and employment stability at the facility.

It is important to point out, that under the traditional permitting approach 3M Hutchinson is now returning to, most if not all of the nine items listed will not be achieved. Even if 3M decides to pursue some of the above features, the incentive and priority will be removed without the Project XL agreement.

In conclusion, we all firmly believe that this pilot Project XL permit for the 3M Hutchinson facility should be allowed to move forward, not only for the reasons outlined above, but for the following common sense reasoning:

-if federal environmental laws like the Clean Air Act and Clean Water Act were passed for the purpose of protecting public health and the environment;

- if we are certain that a Project XL permit will not only ensure such protection but go beyond what we've come to expect in terms of overall environmental performance;

- then we are sacrificing nothing and can only gain from our experiences as we try innovative approaches like the 3M Hutchinson Project XL pilot.

Therefore, please reconsider your decision and let the Project XL experiment be implemented at the 3M Hutchinson facility.

Sincerely,

Pilot Project Committee

The Pilot Project Committee (PPC) is a diverse stakeholder group formed to provide input into the development of the Project XL program in Minnesota. The following are PPC facilitators and members:

Facilitators:
Don Geffen - Research Associate, SMRC, Univ. of MN
Anne Frisch - Minnesota Environmental Initiative
Alfted Marcus - Professor, SMRC, Univ. of MN

Members:
Jon Bloomberg - Attorney, Oppenheimer Wolff & Donnelly
Pam Graika - Director of Environment, Northern States Power
Vint Johnson - Senior Indst. Hygienist, Deluxe Corporation
Brian Lim - Environmental Services Manager, H.B. Fuller
Lee Paddock - Director Env. Policy, MN. Att. General's Off
Ken Sexton - Professor, School of Public Health, Univ. of MN
Brett Smith - Conservation Chair, Sierra Club North Star Chapter
Carol Wiessner - Attorney, MN Center for Env. Advocacy
Larry Sibik - Mgr. Indus. Services, Pinnacle Engineering
Eric Yost -Envir. Engineer, Barr Engineering

3M: Hutchinson, Minnesota

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