# **3M Company -- Menomonie Plant**

**Baseline Report for the Cooperative Agreement**

**Between 3M and the Department of Natural Resources**

**April 1, 2003**

> **Introduction**
>
> On October 1, 2002, following a 30 day public comment period, the
> Wisconsin Department of Natural Resources (WDNR) and 3M Company -
> Menomonie signed a Cooperative Environmental Agreement (CEA) for the
> purpose of providing a reduced air emissions cap, waste reduction
> based on production activity, and operation flexibility.
>
> The CEA began the Title V air permitting process to produce a
> facility-wide air permit for 3M Company - Menomonie. The operating
> permit for the facility will combine environmental management
> commitments beyond those ordinarily required by WDNR rules with
> operational flexibility for the manufacturing facility proportional to
> environmental gains. The permit will reduce the facility\'s existing
> allowable volatile organic compound (VOC) emissions of more than 400
> tons per year (tpy), as authorized by the combination of existing air
> permits, to a VOC emission cap of 249 tpy. The facility will be
> subject to any changes promulgated by New Source Review (NSR)
> applicable to the facility for the duration of the Agreement. The
> resulting facility-wide permit will establish 3M Company - Menomonie
> as a synthetic minor source for purposes of Prevention of Significant
> Deterioration (PSD) rules contingent upon rules promulgated and
> applicable to the facility for the duration of this Agreement.
>
> In exchange for agreeing to comply with more stringent limitations
> than currently required, 3M Company -Menomonie and the WDNR will
> design operational flexibility into the agreement that would be
> accomplished through a number of pre-approved facility changes,
> subject to the limitations expressed in section XI of this agreement.
> All such requirements would be identical to corresponding requirements
> that would be put in place had the pre-approved project been permitted
> under WDNR\'s existing permitting workflow.
>
> This Environmental Cooperative Agreement also includes an Interested
> Persons Group according to section VII. The group will provide
> consultation to the facility during the Title V permit process and
> will continue to provide a valuable, additional channel of
> communication between 3M and the surrounding community during the life
> of the Agreement.
>
> This Agreement was developed under Wisconsin's Environmental
> Cooperation Pilot Program pursuant to Section 299.80, Wis. Statutes,
> to evaluate innovative environmental regulatory methods including
> whole-facility regulation.
>
> **Background**

3M Company is a worldwide supplier of consumer and industrial products
and offers a full range of these products and support services for their
entire customer markets. The 3M Company vision is to be the most
innovative enterprise and the preferred supplier to their customers.

The 3M Company - Menomonie facility consists of a variety of specialized
business units that develop and market various products for consumer and
industrial use. The site manufactures a variety of products including:

-   Brightness enhancement film for electronic displays

-   Adhesive film for flexible printing circuits & automotive
    weather-stripping

-   Vacuum metal-coated products used in optical, protective,
    conductive, or reflective applications

-   Micro-abrasives for the semiconductor industry

-   Re-closeable hook fastening products

-   Coated adhesive tapes for the electrical products markets

-   High temperature ceramic fibers

-   Electromagnetic detection strips used in library books and other
    items for security applications

-   Reflective sheeting used in the traffic sign and traffic
    construction safety industries

-   Membrane electrode assemblies (MEA\'s) to the power industry

The business concept of this facility is that each business unit manage
its projects, while the site staff groups (part of the Optical Systems
Division group of the corporation) will provide the essential staff
services. The staff group consists of the Environmental, Health, Safety,
& Security group, Human Resource Administration, Information Technology
Support, Plant Engineering, and Logistics.

The present 3M Company -- Menomonie site charter is to provide a
long-term semi-works site near 3M Center laboratories, which provides
early manufacturing capability. Another essential part of the charter is
to provide a long term manufacturing site for high technology and
state-of-the-art product lines with the resident site staff maintaining
responsibility for overall site management.

The 3M Company is committed to its environmental responsibilities to
protect its employees and the communities in which they reside. 3M is
proud of their record of environmental stewardship and commitment. Since
1990, 3M operations worldwide have reduced volatile organic air
emissions by 92 percent and manufacturing releases to water by 84
percent. 3M is continuously working on new manufacturing processes and
new formulations to help bring emissions down even further. 3M has a
corporate goal of reducing TRI (toxic release inventory) emissions per
pound of product 50 percent by 2006. In October of 2002, 3M was
presented with the Keep America Beautiful 2002 Vision for America Award
for 3M\'s history of environmental accomplishments and vision for
sustainable development. In announcing the annual award, KAB noted 3M\'s
early dedication to continuously minimize environmental impact as far
back as 1975 when the environmental movement was first gaining momentum
in America.

3M Company has had an active environmental program since 1975. A
long-standing 3M environmental business program, established that same
year, entitled the 3P program (Pollution Prevention Pays) has been
employed to identify environmental opportunities for the site. 3P has
become an integral part of 3M\'s culture and has reduced costs and
improved efficiency, and has helped make 3M Company a model of
environmental management. Pollution prevention activities have also been
promoted through a series of internal cost reduction and waste
minimization programs such as Challenge 95 (1990-1995), Environmental
Goals 2000 (1996 -- 2000) and the current program entitled Environmental
Targets 2005 (ET'05).

In December 2000 3M Company - Menomonie received ISO 14001 registration,
an international environmental management standard, by a third party
auditor. Besides its own internal programs, the facility has been
recognized for its environmental stewardship by the State of Wisconsin
and the Environmental Protection Agency (EPA). In March, 2001 the
facility received the Governor's Award for Excellence in Hazardous Waste
Reduction and in June was recognized as the recipient of the John Brogan
Environmental Achievement Award, the WDNR's highest form of recognition
given to a business, local government, or a nonprofit organization for
outstanding achievements in environmental protection. In August 2002 the
EPA recognized the plant as qualified for membership into the National
Environmental Performance Track (NEPT) program. The NEPT is a voluntary
partnership program that recognizes and encourages top environmental
performers to go beyond compliance with environmental regulations and
commit to continuous environmental improvement.

Under Section XII of the Agreement, 3M Company - Menomonie agrees to
submit a baseline report within 180 days of the signing. The following
report reflects the performance evaluation conducted pursuant to the
Agreement. It has been shared with the Interested Persons Group and is
available for public inspection at the 3M Company--Menomonie facility or
can be obtained by requesting a paper copy or by e-mail.

## Baseline Performance Evaluation

> **Regarding the Interested Persons Group:**

The 3M Company--Menomonie Interested Persons Group is composed of
representatives from business, government and academia in the Menomonie
area who are interested in environmental stewardship and the impact of
manufacturing on local communities. The first initial meeting was held
on August 15, 2002. This was prior to the Cooperative Environmental
Agreement (CEA) 30-day public comment period that began September 1,
2002 and before the actual agreement signing on October 1, 2002. This
meeting was conducted to give the attendees background information on
the CEA program and a general overview of the Menomonie facility.
Information was shared about Menomonie's overall organization and the
type of manufacturing being conducted at the facility. An overview was
presented of existing environmental permits, current regulatory
applicability, current permitting constraints, past environmental
performance, the 2002 Environmental Management System (EMS), progress
towards 2002 EMS objectives and targets, an overview of the 3P Program,
and proposed pre-approval protocol offered by 3M.

Group members include the following individuals:

-   Mike Beaupre, Director, Indianhead Enterprises

-   Keith Bergeson, Dunn County Department of Public Health

-   Mark Harings, Wisconsin Department of Natural Resources

-   Edward M. Jenson, Superintendent, Menomonie Wastewater Utility

-   Dr. Martin Ondrus, UW-Stout, Chemistry Department

-   Ed Smith, Menomonie City Council Member and Plan Commission Member

-   Barbara Thomas, current chair of the Chippewa Valley (WI) group of
    the Sierra Club

> **Regarding ISO 14001 Recertification and Evaluation of the EMS:**

The third party auditor reissued recertification of the EMS to
conformance to the ISO 14001 standard to the facility on December 7,
2002. This completed the two-year cycle of surveillance audits that
reviewed all elements of the EMS. The two surveillance audits conducted
in 2002 resulted in one action request and ten observations noted
concerning the EMS. The action request has been cleared and the
observations for system improvements have been addressed. A copy of the
current registration certificate, issued by the third party auditor,
Underwriters Laboratories (UL), is on their website. Go to the Internet
address <http://www.ul.com/> and search for file \# A8582 in the
certifications menu.

> **Regarding a Summary of 2002 EMS Targets & Objectives:**
>
> The 3M-Menomonie facility has identified its environmental aspects and
> ranked them based on the significance of their environmental impact.
> Objectives and targets for 2002 were developed in December 2001 and
> approved by upper management in January 2002. Several of the targets
> and objectives are based around the Environmental Targets 2005
> environmental initiatives (waste, VOCs, TRI chemical releases).
>
> The 3M Company - Menomonie facility adopted the following
> Environmental Objectives and Targets for 2002 at Management Review on
> January 28, 2002:

+----------------------+---------+-------------------+----------------+
| > **[Objective       | > **[I  | > **[Aspec        | > **[          |
| > #1:]{.underline}** | mpact:] | t:]{.underline}** | Significance:] |
| >                    | {.under | >                 | {.underline}** |
| > Submit at least    | line}** | > Process and     | >              |
| > one approved 3P    | >       | > plant           | > Reduction of |
| > project in 2002    | > Waste | > activities and  | > overall      |
|                      | > re    | > services        | > waste or     |
|                      | duction | > related to      | >              |
|                      |         | > waste and       |  environmental |
|                      |         | > energy          | > releases     |
|                      |         | > reduction       | > from the     |
|                      |         |                   | > site         |
+----------------------+---------+-------------------+----------------+

+-----------------------------------------------------------------------+
| > **[Target #1:]{.underline}**                                        |
| >                                                                     |
| > Submit at least one approved 3P project for the facility by         |
| > 12/31/2002.                                                         |
+-----------------------------------------------------------------------+

+-----------------------------------------------------------------------+
| > **[Details:]{.underline}**                                          |
| >                                                                     |
| > The goal is a total of 6 approved 3P program submittals by the end  |
| > of 2005. Three approved projects were submitted in 2001. Therefore, |
| > at least 3 new projects ideas are needed in 2002-2005.              |
+-----------------------------------------------------------------------+

> **[Results:]{.underline}**
>
> A 3P program was submitted and approved on 9/24/2002 to reduce the
> generation of scrap hot melt adhesive on a tape coater by adhering to
> the following objectives:
>
> 1\. Compounder material throughput reduction during downtimes less
> than 1/2 hour.
>
> 2\. Compounder shutdown during downtimes exceeding 1/2 hour.
>
> 3\. Limitation of experimental adhesive generation through dedication
> to higher factor designed experiments.
>
> 4\. Increasing the effectiveness of purge operations.
>
> 5\. Sequencing and scheduling products to minimize the need for purge
> operations.
>
> 6\. Implementing start-up procedures focusing on minimizing adhesive
> output.
>
> In 2001, \$5,883 was saved in disposal costs and \$166,500 in raw
> materials. This project also reduced waste produced (hazardous and
> solid waste) by 111 tons.

+----------------------+-----------+---------------+------------------+
| > **[Objective       | > **[Impa | >             | >                |
| > #2:]{.underline}** | ct:]{.und |  **[Aspect:]{ |  **[Significance |
| >                    | erline}** | .underline}** | :]{.underline}** |
| > Develop and        | >         | >             | >                |
| > institute an       | >         | > Site        | > Simplify       |
| > integrated         | Emergency | > emergency   | > emergency      |
| > contingency plan   | > Pre     | >             | > planning and   |
| > (ICP) for          | paredness |  preparedness | > response based |
| > emergency          |           |               | > on the         |
| > situations         |           |               | > scenario       |
+----------------------+-----------+---------------+------------------+

+-----------------------------------------------------------------------+
| > **[Target #2:]{.underline}**                                        |
| >                                                                     |
| > Develop and institute an ICP by 12/31/2002                          |
+-----------------------------------------------------------------------+

+-----------------------------------------------------------------------+
| > **[Details:]{.underline}**                                          |
| >                                                                     |
| > The ICP will place into one single plan the following legally       |
| > required plans that call for emergency response planning: OSHA      |
| > HAZWOPER plan, RCRA contingency plan, LEPC plan, OSHA Emergency     |
| > Action Plan, OSHA & 3M PSM standard/guidelines, EPA SPCC spill      |
| > plan, EPA RMP \"general duty" clause.                               |
+-----------------------------------------------------------------------+

**[Results:]{.underline}**

The basic outline for the plan was developed using the USEPA template
document. Development continues on the plan. This will carry over into
2003. Flowcharting of various emergency scenarios are being completed
for the plan. An example of the emergency flowchart for an anhydrous
ammonia release is shown in Attachment A.

+-----------------------+-----------+----------------+----------------+
| > **[Objective        | > **[Impa | > **[Aspect:]  | > **[          |
| > #3:]{.underline}**  | ct:]{.und | {.underline}** | Significance:] |
| >                     | erline}** | >              | {.underline}** |
| > Convert the WSPs    | >         | > Plant        | >              |
| > (waste stream       | >         | > activities   | > Take         |
| > profiles) that      | Hazardous | > related to   | > advantage of |
| > qualify under the   | > waste   | > the          | > the          |
| > universal waste     | >         | > generation   | > universal    |
| > exemption (light    | reduction | > of waste     | > waste        |
| > bulbs, lamps etc.)  |           | > classified   | > exemption    |
| > to decrease the     |           | > under the    | > that had not |
| > total pounds of     |           | > universal    | > been         |
| > hazardous waste     |           | > waste        | > previously   |
| > shipments by 1 %    |           | > category     | > used by the  |
| > from 2001 levels    |           |                | > facility     |
+-----------------------+-----------+----------------+----------------+

> **[Target #3:]{.underline}**

Reduce hazardous waste levels by 1% by reclassifying waste stream
profiles that can qualify under the universal waste exemption.

**[Details:]{.underline}**

Investigate converting the following WSPs to the universal waste
exemption: mercury switches, spent fluorescent bulbs, HP/mercury vapor
lamps, and PC boards.

**[Results:]{.underline}**

A reduction of the total hazardous waste pounds was achieved by
recycling fluorescent lamps and other lighting bulbs (HID, mercury
vapor, HPS) through the Lamptracker UPS program. The goal of this target
was a 1% or greater reduction. The internal change went into effect in
April 2002, with the plant's first shipment of bulbs occurring in
September 2002. The actual reduction from 2001 was 0.6% as the target
might have been achieved if the program had been started earlier in
2002.

+------------------+-------------+-------------------+----------------+
| > **[Objective   | > **[       | > **[Aspec        | > **[          |
| > #4             | Impact:]{.u | t:]{.underline}** | Significance:] |
| :]{.underline}** | nderline}** | >                 | {.underline}** |
| >                | >           | > VOC-producing   | >              |
| > Reduce VOC     | > VOC air   | > processes in    | > A 5%         |
| > (volatile      | > emissions | > identified      | > reduction    |
| > organic        |             | > departments     | > each year is |
| > compounds)     |             |                   | > required to  |
| > emissions per  |             |                   | > meet the     |
| > pound of good  |             |                   | > corporate    |
| > output by 5%   |             |                   | > goal of a    |
| > in 2002 as     |             |                   | > 25%          |
| > compared to    |             |                   | > reduction by |
| > 2001.          |             |                   | > the end of   |
|                  |             |                   | > 2005 (2000   |
|                  |             |                   | > base year)   |
+------------------+-------------+-------------------+----------------+

+-----------------------------------------------------------------------+
| > **[Target #4:]{.underline}**                                        |
| >                                                                     |
| > Reduce \# VOC/ \# good output (finished, semi-finished, by-product) |
| > by 5% from previous year (2001).                                    |
+-----------------------------------------------------------------------+

**[Results:]{.underline}**

There was a 17% increase in pounds of VOCs released/pound of good output
in 2002 as compared to 2001, but the facility has shown a 13% overall
decrease in VOCs released since the base year 2000. The facility remains
on target to meet the 25% reduction goal by the end of 2005. Refer to
Figure 1 below.

![](media/image2.wmf)

+------------------+----------------+-------------+-------------------+
| > **[Objective   | > **[Impact:]  | > **[       | > **[Significanc  |
| > #5             | {.underline}** | Aspect:]{.u | e:]{.underline}** |
| :]{.underline}** | >              | nderline}** | >                 |
| >                | > Waste        | >           | > Corporate       |
| > Reduce by 10%  | > reduction    | > Processes | > ET\'05 goal of  |
| > reportable     |                | > related   | > a 50% reduction |
| > releases of    |                | > to TRI    | > in the release  |
| > TRI (Toxic     |                | > air       | > of TRI          |
| > Release        |                | > releases  | > reportable      |
| > Inventory)     |                |             | > chemicals/pound |
| > chemicals      |                |             | > of good output  |
| > reported in    |                |             | > by 2006.        |
| > 2000 / pound   |                |             |                   |
| > of good output |                |             |                   |
| > in 2001.       |                |             |                   |
+------------------+----------------+-------------+-------------------+

+-----------------------------------------------------------------------+
| > **[Target #5:]{.underline}**                                        |
| >                                                                     |
| > Reduce 2001 reportable TRI air emissions/ \# good output by 10%     |
| > compared to year 2000 reported TRI releases.                        |
+-----------------------------------------------------------------------+

**[Results:]{.underline}**

The reportable TRI chemical release goal showed a 33% reduction compared
to 2001. This is shown in Figure 2.

![](media/image3.wmf)

+--------------------+----------+-----------------+--------------------+
| > **[Objective \#  | > *      | > **[Aspect:    | > **[Significan    |
| >                  | *[Impact | ]{.underline}** | ce:]{.underline}** |
|  6:]{.underline}** | :]{.unde | >               | >                  |
| >                  | rline}** | > Activities,   | > A 5% reduction   |
| > Reduce solid &   | >        | > products, and | > each year is     |
| > chemical waste   | > Waste  | > services      | > required to meet |
| > produced/pound   | > r      | > (APS) that    | > the corporate    |
| > of good output   | eduction | > produce solid | > goal of a 25%    |
| > another 5% in    |          | > and chemical  | > reduction by the |
| > 2002 as compared |          | > waste         | > end of 2005      |
| > to 2001.         |          | > materials     | > (2000 base year) |
+--------------------+----------+-----------------+--------------------+

**[Target \# 6:]{.underline}**

Reduce solid and chemical waste/ \# good output by 5% in 2002 based on
levels reported in 2001.

+-----------------------------------------------------------------------+
| > **[Details:]{.underline}**                                          |
| >                                                                     |
| > Set up planning/review meetings with all departments to discuss and |
| > track short term and long term plans to reduce wastes. Discuss      |
| > possible 3P and Six Sigma projects for waste reductions. Track      |
| > emissions and report quarterly under the 3M ET\'05 goals program.   |
+-----------------------------------------------------------------------+

**[Results:]{.underline}**

The facility achieved a 14% reduction of waste (solid & chemical
hazardous and non-hazardous waste) / \# good output in 2002 as compared
to 2001. Refer to Figure 3.

![](media/image4.wmf)

> **Regarding Changes to the 2003 EMS Targets & Objectives:**
>
> Listed below are the 2003 EMS Objectives and Targets. The ET'05
> program objectives continue with an additional 5% reduction from
> previous year performance in VOC emissions and waste produced per
> pound of good output. This is consistent with the five-year plan to
> reduce these wastes 25% by the end of 2005. The reduction of TRI
> chemical releases to stay on target to reduce these releases by 50%
> per pound of good output has also been identified as a 2003 objective
> and target. In addition, the completion of the ICP plan has been
> targeted for a mid-year completion and the EMS documentation system
> will be migrated to another database that is supported by corporate
> information technology.
>
> 2003 EMS Objectives & Targets

-   Develop and institute the ICP by 6/1/2003.

-   Reduce releases of reportable TRI chemicals/ pound of good output
    another 10% in 2003 to keep pace with the overall objective of a 50%
    reduction/pound of good output by the end of 2005 (1999 base year).

-   Reduce VOC emissions per pound of good output another 5% in 2003 to
    keep pace with reducing overall VOC emissions 25% per pound of good
    output by the end of 2005 (2000 as the base year).

-   Reduce waste/pound of good output another 5% in 2003 to keep pace
    with an overall 25% reduction by the end of 2005.

-   Submit at least one approved 3P (Pollution Prevention Pays) project
    in 2003.

-   Meet the requirements of the Wisconsin DNR Cooperative Environmental
    Agreement and the USEPA National Environmental Performance Track for
    2003.

-   Migrate the EMS documentation system to the QDS (Quality Document
    System) that is consistent with the facility quality, manufacturing,
    and other EHS (environmental, health, and safety) document systems.

> **Regarding Actual Waste Reductions:**
>
> A summary of 2001/2002 3M-Menomonie wastes and air emissions is shown
> in Table 1:
>
> Table 1: 2002/2001 Waste & Air Emissions

  ---------------- ------------ ------------ ----------- ------------------
  Type of Waste    2002         2001         \% Change   Comment

  Regulated        127,650 lb.  129,761 lb.  \- 1.7%     All hazardous
  Hazardous Waste:                                       waste sent to
                                                         corporate waste
                                                         incinerator,
                                                         Cottage Grove, MN.

  Parts washer     505 lb.      867          \- 42%      Sent to
  solvents                                               Safety-Kleen,
                                                         Lacrosse, WI

  Non-regulated    96,946 lb.   74,852       \+ 23 %     Sent to corporate
  chemical waste                                         incinerator

  Landfill waste   373, 716 lb. 553,860 lb.  \- 33 %     Sent to Dunn
                                                         County Waste
                                                         Management

  Secured solid    1,214,487    1,087,558    \+ 10.5 %   Sent to secured
  Waste            lb.                                   waste facility for
                                                         energy burn

  General solid    669,094 lb.  676,080      \- 1.0 %    Sent to Barron Co.
  waste                                                  Incinerator for
                                                         energy burn

  VOC emissions    161,612 lb.  131,637      \+ 18.5 %   Reported on WDNR
                                                         annual air
                                                         emissions
                                                         inventory (AEI)

  HAP (hazardous   113,064      91,673       \+ 19.0 %   Reported on WDNR
  air pollutants)                                        annual air
  emissions                                              emissions
                                                         inventory (AEI)

  Reportable TRI   104,000      84,500       \+ 18.8 %   Reported on EPCRA
  chemical         (est.)                                313 annual report
  releases                                               
  ---------------- ------------ ------------ ----------- ------------------

> Waste and emissions "normalized" or adjusted for changes in production
> activity during these same periods are shown in Attachment B at the
> end of this report.
>
> **Regarding any Public Inquiries or Complaints Concerning the
> Agreement:**
>
> 3M Company-Menomonie is not aware of any public inquires or complaints
> concerning this agreement that has been brought directly to their
> attention during the 30 day public comment period or the subsequent
> time since the agreement was signed on 10/1/2002.
>
> **Regarding any Non-performance with the Agreement from the Previous
> Year:**
>
> 3M Company -- Menomonie is not aware of any non-performance issues
> related to this agreement at this time.
>
> **Regarding any Success/Improvements not Specifically Outlined in the
> Agreement:**
>
> The following environmental gains have been accomplished due in part
> to internal environmental programs and development of the EMS to show
> continuous improvement in the environmental management system:

-   Six Sigma (a 3M formalized problem solving/decision making process)
    projects identified to improve record keeping requirements and
    reduce solvent emissions on a plant tape coating line.

-   Expanded use of the universal waste exemption to recycle lamps,
    heavy metal batteries, lighting ballasts through the use of the
    Lamptracker UPS program

-   Tracking solid and chemical wastes using an environmental accounting
    system called the Menomonie Waste Control System (WCS) developed
    from a plant inventory control system.

-   Documentation of the hazardous waste process through the use of
    flowcharting -- handling, labeling, manifesting, shipping
    requirements, etc

-   Work instructions in EMS on hazardous waste label printing for
    departmental use

-   Menomonie ET\'05 database (spreadsheets/charting) to track quarterly
    performance of environmental goals

-   NEPT acceptance committed to environmental improvements (waste
    reductions) by 2004

-   Electronic incident reporting & investigation system that includes
    corrective/preventive action item assignment and follow-up

-   Corporate EHS (environmental, health, & safety) Scorecard/CIP
    (continuous improvement plan) requirements that include
    environmental performance requirements (ET\'05 goals) and regular
    management review

-   Electronic training and documentation of EMS awareness and annual
    waste training topics (self-study)

-   More formalized Emergency Response Team (ERT) exercises/drill
    concerning environmental spills

-   Actively working with corporate Reverse Supply Chain Services to
    find markets for various adhesives and plastic films that previously
    had to be sent to the landfill or sent to a secured waste site for
    disposal

-   Wet scrubber air emission control added to CF-5 ceramic fibers
    furnace to reduce air emissions

> **Regarding Operational Flexibility:**
>
> 3M-Menomonie and the WDNR met on 10/25/2002 to discuss and establish a
> timeline for development of the Title V permit that identifies
> conditions of operations while under the CEA. Wendy Reno, Menomonie's
> Corporate Environmental Engineering contact, submitted the revised
> Title V application to the WDNR on 01/07/2003 for their review. A
> meeting was held at 3M-Menomonie on 2/11/2003 to clarify information
> submitted in the application. 3M provided the WDNR with an example of
> "flexible permitting" that expedited the construction and operating
> permit process.
>
> Since the signing of this agreement on October 1, 2002, 3M has
> requested two new construction permits for new air sources. In
> addition, 3M was issued an operating permit for the Optical Systems
> Division to allow modification of the permit to begin construction of
> a new process line for production of brightness enhancement film.
> Since the final operational flexibility of this agreement has not been
> determined at the time of this report, no evaluation can be conducted
> concerning the reduction of record keeping and administrative
> requirements due to these changes.
>
> The key milestone of the Agreement was to have the facility--wide
> Title V air permit submitted and approved by the second quarter, 2004.
>
> Additional time requirements for fulfilling this agreement include:
>
> [Requirements Added:]{.underline} [Additional Time
> Required:]{.underline}
>
> Preparation and submittal of new Title V air permit application 240
> hours
>
> Compiling this Baseline Report 40 hours
>
> Managing the Interested Persons Group 18 hours/year
>
> At this time there have been no changes in the management of the
> existing air permits or required reporting or record keeping to
> determine reductions in time related to this activity.
>
> **Regarding Overall Assessment of the Success of the Agreement:**
>
> Since this is the 180-day baseline report, no specific assessment can
> be made at this time concerning the agreement. 3M Company - Menomonie
> feels that success of the agreement relies on obtaining the
> facility-wide Title V operating permit in a timely manner and
> finalizing the process of operational flexibility as outlined in the
> Agreement.
>
> Questions and requests for additional information should be directed
> to Michael Wendt, EHS Department, at the address below:
>
> 3M Company -- Menomonie Plant

1425 Stokke Parkway

Menomonie, WI 54751

Phone: 715/235-5541

E-mail: <mrwendt1@mmm.com>

Attachment A: Example Flowchart from ICP

![](media/image5.wmf)

Attachment B: 2002/2001 Wastes Normalized for Production Activity

(All waste in pounds)

# **2002 Normalizing Factor** 

[Lb. of good output produced in 2002]{.underline} = [23,512]{.underline}
x 10^3^ = 1.13

Lb. of good output produced in 2001 20,848 x 10^3^

# **2002 Normalized Waste Quantity** 

## [Lb. of waste produced in 2002]{.underline}

2002 Normalizing Factor

[Example:]{.underline} [Lb. 2002 Regulated Hazardous Waste]{.underline}
= [127,650]{.underline} = 112,965

2002 Normalizing Factor 1.13

+--------------+------------+------------+---------------+------------+
| Type of      | 2001       | 2002       | 2002          | \% Change  |
| Waste        |            |            |               |            |
|              | (Actual)   | (Actual)   | (Normalized)  |            |
+--------------+------------+------------+---------------+------------+
| Regulated    | 129,761    | 127,650    | 112,965       | \- 12%     |
| Hazardous    |            |            |               |            |
| Waste:       |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| Parts washer | 867        | 505 lb.    | 447           | \- 48%     |
| solvents     |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| N            | 74,852     | 96,946     | 85,793        | \+ 15 %    |
| on-regulated |            |            |               |            |
| chemical     |            |            |               |            |
| waste        |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| Landfill     | 553,860    | 373, 716.  | 330,732       | \- 40 %    |
| waste        |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| Secured      | 1,087,558  | 1,214,487  | 1,074,767     | \- 1 %     |
| solid Waste  |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| General      | 676,080    | 669,094    | 592,119       | \- 12.0 %  |
| solid waste  |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| VOC          | 131,637    | 161,612    | 143,019       | \+ 9 %     |
| emissions    |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| HAP          | 91,673     | 113,064    | 100,057       | \+ 9 %     |
| (hazardous   |            |            |               |            |
| air          |            |            |               |            |
| pollutants)  |            |            |               |            |
| emissions    |            |            |               |            |
+--------------+------------+------------+---------------+------------+
| Reportable   | 84,500     | 104,000    | 92,478        | \+ 9 %     |
| TRI chemical |            | (est.)     |               |            |
| releases     |            |            |               |            |
+--------------+------------+------------+---------------+------------+