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3M: Hutchinson, Minnesota

3M: OAR Rationale for MAG TAPE Averaging

(for allowing use of past voluntary controls)

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 shut down or significantly modified a short time later. For such operations, controls may not be reasonable. This is an unusual, sitespecific problem not foreseen during development of the mag tape NESHAP.

As previously stated, EPA believes that past voluntary controls generally should not be included in assessing whether an XL project will achieve the actual emissions 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 magnetic tape NESHAP. A separate averaging system would be established for HAPs from the mag tape facility as an alternative means of compliance. The averaging system would have the following elements:

- the credits generated thru averaging must be adjusted by a factor of 10% to reflect the MACT emissions averaging discount approach (HON is the example).

- An additional factor of 2% overall control would also be assessed to account for the margin that a source normally reserves to ensure that they do not exceed the required standard. This would be added to the 95% MACT control requirement. Thus the adjusted required control would be 97%.

- No credit from the mag tape controls can be counted against any other non mag tape emissions or emission points.

- The rest of the project is still governed by the actuals to actuals test.

-Once the mag tape MACT is no longer applicable to the plant, the entire plant would be governed by the actuals to actuals test.

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