p.1 

OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

10)11-1-2 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:18 AM Sheet 10 of 142 
P.2 

Or. Robert P. Sringer 

Saft Vice President 

A- °l0-3-] 

February 18, 1992 •••'" ;.-,-.. _ _ _ 

'"•^ I'M. :-^'^*"ivCri 

Commissioner Charles W. Williams 

Minnesota Pollution Control Agency 

520 Lafayette Road, Sixth Floor 

St. Paul, Minnesota 55155 

Dear Commissioner Williams: 

On January 31, 1992, 3M met with your staff to discuss 

our proposed "Source-wide" Air Emission Reduction 

Permit for the St. Paul Tape Manufacturing Division 

plant. 3M has included agency input from that meeting 

in the attached Innovative "Source-wide" Air Emission 

Reduction Permitting Proposal that is being submitted 

for consideration by you and your staff. 

Lisa Thorvig has already scheduled a meeting with U.S. 

EPA Region V in Chicago for March 6, 1992, to discuss 

the proposal in detail. By copy of this letter, I am 

also submitting the proposal to the U.S. EPA Region V 

offices in Chicago in order to conserve time and to 

provide them with an advance copy to review before the 

meeting. 

3M is committed to reducing VOC emissions from our 

St. Paul Tape Manufacturing Division plant and is 

looking forward to working with the MPCA and U.S. EPA 

to develop this innovative proposal. 

If you have any questions or suggestions regarding 

these issues, please contact me at 778-4331 at your 

convenience. 

Sincerely, 

Enclosure 

cc: George Czerniak - U.S. EPA 

David Kee - U.S. EPA 

Jeffry Muffat - 3M 

Michael Santoro - 3M 

Lisa Thorvig - MPCA 

31.'. Erv.-rorjnC'rual F.n<)ir*rf.r!nc 
280'39tf d 

20-d IdlO l 

P.3 

91 -IM 26 . 2 yyw 

3M Environmental Engineering 

and Pollution Control 

PO Box 33331 

St. Paul. MN 55133-3331 

652/778 4335 . 

» • 

3M 

INNOVATIVE "SOURCE-WIDE" AIR EMISSION REDUCTION 

PERMITTING PROPOS-AIi FOR THE 3M ST. PAUL, MN 

T.APE MANUFACTURING DIVISION PLANT 

SUMMARY OF PROPOSAL 

3M is proposing that the Tape Manufacturing Division plant located 

in St. Paul, MN, be issued a single air emission permit for the 

entire plant which would include all stationary and fugitive 

sources of VOC emissions and would reduce actual, plant wide VOC 

emissions to levels well below recent, actual emission levels. 

Specifically, 3M is proposing to commit to a cap on VOC emissions 

from the entire stationary source that would be significantly less 

than state or federal regulations require. Compliance with this 

cap will be accomplished through the use of two new, voluntarilyinstalled thermal oxidizers constructed as part of 3M's Pollution 

Prevention Plus Program. In consideration of this enforceable 

commitment, 3M requests regulatory and permitting flexibility in 

the handling of future process or productivity improvements made 

on equipment or operations'at the source. 

If the company does not implement the proposal, the PSD rules 

would allow actual emissions at the plant to rise significantly as 

a result of normal operations, modifications or both over the next 

five years without triggering PSD review. The proposal as 

outlined below provides for a federally enforceable "cap" on 

actual emissions for the plant at less than half that level and 

addresses the PSD ramifications of improvements made at the source 

within the framework of the existing PSD rules. 

A new, innovative, extensive emissions monitoring and reporting 

system described below would be implemented as a result of the 

issuance of a source-wide air emission permit. This system would 

be set up to track emissions on a daily basis throughout the 

entire source and to ensure that the emissions cap is not exceeded 

in any given year. -" 
PA_ 

£00-"39dd CI '-SI 26. 2 dtfM 

Page 2 

This proposal also addresses the issue of the federal 

enforceability of the proposal, in terms of both regulatory 

enforceability and practical enforceability. 3M is considering 

various options to establish the enforceability of the permit cap, 

including emission averages over various time periods or permit 

conditions requiring the operation of the thermal oxidizer 

(including breakdown/malfunction contingencies). 3M is soliciting 

constructive agency comments on how these compliance mechanisms, 

or combinations of them, could best meet agency and 3M goals' in a 

workable manner. 

This proposal accomplishes the actual emission reduction goals of 

the MPCA, U.S.EPA, and 3M while providing significant permanent, 

actual environmental benefits. It provides far more absolute and 

timely actual emission reductions than would be achieved by the 

"netting-out" of any individual changes through the traditional 

PSD review process. The source-wide cap eliminates the timeconsuming agency review process and "netting-out" process and 

frees agency resources to address other, more pressing permitting 

issues. The cap provides 3M the security that it may proceed with 

changes at the plant without fear of the uncertain PSD definitions 

and other complicated PSD provisions. Finally, a source-wide 

permit with,an emissions cap would provide for "federally 

enforceable" limits to ensure compliance while allowing 3M the 

flexibility to determine how best to operate the plant within the 

confines of the VOC emission limits in the permit. 

I. BACKGROUND 

3M operates a Tape Manufacturing Division plant located at 900 

Bush Avenue in St. Paul, MN. The 2000+ different finished and 

semi-finished products manufactured at this plant are 

predominantly classified as pressure sensitive tape and label 

products. They are primarily manufactured by coating various 

solutions containing proprietary solids and solvents (VOCs) onto a 

substrate of paper or film (web), After the web is coated it goes 

through a series of ovens to dry the products by evaporating the 

VOCs. (The equipment used to coat and dry these products is 

referred to as a coater.) This evaporation process is the major 

source of VOC emissions to the atmosphere. The storage, piping, 

mixing, and miscellaneous operations make up the re.mainder of VOC 

emissions to the atmosphere. All of the activities of the 

St. Paul Tape Plant belong to the same "Major Group" SIC Code 

(i.e., 2-digit Code Number 26 entitled Paper and Allied Products), 

all are located on one contiguous 3M property and all are under 

the control of 3M. They are therefore all one "stationary source" 

for PSD purposes (see Section 52.21(b) (S), (6)) . 
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The area of St. Paul, MN, in which the plant is located is 

designated by U.S.EPA as attainment for the NAAQS for ozone and, 

therefore, modifications to the source would fall under the PSD 

requirements of the U.S.EPA. 

Over the last several years, 3M has voluntarily installed control 

equipment on all of the coaters at the St. Paul plant. The latest 

of these control programs was the installation of two thermal 

oxidizers to control the VOC emissions from 17 of the coaters plus 

some miscellaneous equipment. Through the installation of these 

controls the 3M Tape Manufacturing Division plant in St. Paul has 

reduced its actual emissions significantly. 

II. MANUFACTURING CHftNgBS 

In addition to their own, the Tape Manufacturing Division plant 

coats products for several different divisions within 3M. Most of 

the products are lower volume, special application products 

manufactured on existing, long-established coaters. In order to 

remain competitive and viable in the specialty tape markets, the 

Division's strategic goals will require it to continually upgrade 

and modernize coating and mixing equipment over the next 1-5 

years. These activities will primarily involve changes or 

upgrades of equipment to replace older, out-moded equipment and 

controls, to improve product quality and to reduce unit costs. To 

the extent these continuous improvements are not made in a timely 

manner, the economic viability and manufacturing reliability of 

the plant is a concern. 

Specifically, it is anticipated that the Division will need to 

replace some older or obsolete equipment, install newer technology 

to improve product quality, consolidate production on some coaters 

to improve efficiency and reduce waste, and provide better and 

more timely service to customers. As part of these activities, 

some of the existing coaters will be removed to make room for 

other productivity improvements. 

As we understand the complex PSD rules, many of these chances 

potentially could involve time-consuming analysis by the M?Ca^, 

U.S.EPA, and 3M to determine the applicability of the PSD rules. 

These rules apply if the changes that are contemplated constitute 

a "major modification," defined in general terms as a physical or 

operational change that results in an increase in emissions. 
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A determination of whether an increase in emissions has occurred 

leads one through a complex formula where, in general terms, 

actual emissions before a change are compared to potential 

emissions following the change. Importantly, however, the 

regulations allow a company to "net-out" of the PSD requirements 

if reductions in emissions occur at the plant which will offset 

any increases. If necessary, the St. Paul Tape plant could "netout" of the PSD requirements. 

A determination of whether a physical change has occurred requires 

a working understanding of a series of PSD exemptions and 

definitions. To determine whether a change qualifies as "routine 

repair and maintenance," as a "change in raw materials," or as a 

"production rate increase" is a challenge for the regulated 

community and for the regulatory agencies. For the types of 

changes contemplated by 3M over the next several years, it is 

simply unclear when and whether the PSD requirements apply. 

This lack of clarity leads to one of two nonproductive results: 

1. 3M must interpret the regulations on its own (as most 

companies do), given the limited guidance provided on the 

subject, and make a determination as to whether a 

modification has occurred. Should a determination be made 

that a modification has not occurred, 3M would not gain much 

assurance that it will not be the subject of some future 

agency audit or other agency action, or 

2. 3M must seek confirmation from the agencies on every change, 

resulting in significant increases in the workload of the 

MPCA's and U.S.EPA's permitting staff and inevitable project 

delays which reduce 3M's competitive edge. 

The length of time presently required to obtain a PSD permit or 

determination is typically 4-12 months or longer. This time frame 

presents a severe constraint in meeting our business objectives, 

especially in today's highly competitive and rapidly changing 

world. For example, during the past year 3M has submitted 

numerous permit applications with the MPCA and, in fact, currently 

has 13 permit applications on file. These applications include 

modifications to existing buildings and/or processes as well as 

new sources. The average time to process these permit 

applications has increased significantly in recent years and 

upcoming state/federal requirements will only increase that 

average because, in part, permits will be required for previously 

unregulated sources and more and more information will be recuired 

in each application. 
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III . SPEPTFTr . PROPQ9AT. 

The issuance of a source-wide permit would address the timing 

concerns of 3M and resource concerns of the MPCA and U.S.EPA in 

the context of a permit that benefits the environment, and that is 

enforceable and manageable. On our part, 3M is prepared to invest 

the resources to gain the flexibility of a cap rather than spend 

excessive time on repetitive, complex permitting exercises. 

This innovative proposal only addresses the VOC emissions from the 

source. It is 3M's intent that the other emissions such as 

particulate, SOx, and NOx would be governed by existing MPCA 

regulations. Of course, if any of the modifications contemplated 

triggers New Source Performance Standards (NSPS) those sources 

would have to comply with the applicable NSPS requirements. 

3M would be willing to accept a permit limit for the entire Tape 

Manufacturing Division plant set at 4500 tons of VOC emissions per 

year. This permit limit would include fugitive emissions as well 

as stack emissions from the facility. In that the potential 

(uncontrolled) VOC emissions at the facility are estimated at 

65,000 tons annually, and actual emissions as recently as 1988 

were 9350 tons, this cap represents a significant reduction in 

potential emissions, allowable emissions, and actual emissions. 

Based on current and future market demands, the plant can meet a 

4500 ton per year cap if the permit contains sufficient 

flexibility. 

The remainder of this memo discusses the various aspects of the 

proposal in detail. 

PSP ISSUES 

As explained above, if the company does not implement this 

proposal, the PSD rules currently would allow actual emissions at 

the plant to rise significantly as a result of normal operations, 

modifications or both over the next five years without triggering 

PSD review. Using the traditional "netting-out" concept, 3M could 

restrict emissions through use of the thermal oxidizer and use the 

reductions to offset increases resulting from modifications. It 

is exactly this step-by-step, project-by-project approach that 3M 

is seeking to avoid with the source-wide permit for the St. Paul 

Tape plant. 

In consideration of taking a 4500 ton per year limit at this time, 

3M proposes permit language which resolves all PSD issues for the 

future as long as the 4500 ton limit, and other permit 

restrictions deemed appropriate to make the permit enforceable, 

are satisfied. For PSD purposes, the permit would provide that 
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the actual emissions, allowable emissions, and potential emissions 

be set at 4500 tons per year. 3M could then make changes to" the 

coaters under a source-wide permit as long as total emissions did 

not exceed the emissions cap. In that there would be no emissions 

increase when comparing actual to potential emissions, no PSD 

issues would be presented. This result can be accomplished 

through use of several current PSD regulations. 

Section 52.21(b) (21)(ii) requires the establishment of a 

representative actual baseline for emissions. The proposed permit 

would contain language establishing the 1991-1992 emissions (4500 

tons per year) as the representative actual baseline for 

calculating PSD applicability for the future. By establishing the 

4500 ton limit as actual emissions, representative actual 

emissions would always equal potential emissions (set at 4500 tons 

by the permit) and no PSD issues would be raised by changes 

occurring at the plant. This approach would allow changes to take 

plac-e at the facility with no agency involvement as long as the 

permit cap limitation is met. 

Additionally, Section 52.21(b)(21)(iii) allows for an agreement 

that the plant-wide 4500 ton limit represents both the "sourcespecific allowable emissions" for all plant units and actual 

emissions for all plant units. Such an agreement would again 

establish actual emissions at the 4500 ton per year level and no 

PSD issues would be raised by changes occurring at the plant 

(again assuming compliance with the 4500 ton limit). 

There are identical provisions in U.S.EPA's regulations 

establishing state requirements for PSD (compare Section 

51.166(b)(21)(ii) with Section 52.21(b)(21)(ii) and 

compare Section 51.166(b)(21)(iii) with Section 

52.21(b) (21) (iii)). In addition, Section 51.166(b) (3)(ii) allows 

the MPCA to specify a reasonable period in the permit during which 

increases and decreases could be used to calculate "net emissions" 

changes at the plant. The proposed permit would specify that all 

increases and decreases after 1988 would count for PSD purposes. 

This would avoid the "moving target" aspect of the PSD rules. 

These and perhaps other PSD provisions offer the opportunity to 

establish the 4500 ton limit in a permit which provides the 

timeliness and flexibility requested by 3M, which conserves the 

resources of the agencies involved, and which represents real 

environmental benefit. 
PJL 

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TNNOVATTVE EMTSSTONS TRACKTNC. AND REPORTING SYSTEM 

In order to track the emissions and report them to the MPCA, 3M is 

proposing to establish a flexible computer based VOC emissions 

reporting system that will integrate with our existing production 

reporting systems and allow us to calculate and document daily 

emissions from our source. Emission calculations will be based on 

daily production reported volumes and usages for each piece of 

production equipment in our facility. 

The St. Paul Tape Plant is a specialty (as opposed to a commodity) 

producer of adhesive tape products. The nature of the specialty 

tape business necessitates that 3M produce a large, constantly 

changing number of different types of finished products and as a 

result an even larger number of intermediate components in the 

manufacture of our product lines. 

Current VOC emissions reporting for the facility is done on an 

annual basis using a mass-balance calculation methodology. This 

methodology relies on the determination of annual usage levels of 

components containing VOCs through an accounting of reported 

receipts, shipments, and inventory levels. Due to the complexity 

of our operations these calculations require a minimum of oneperson month to perform and are completed on an annual basis. 

In conjunction with the issuance of a Source-Wide Air Emission 

Reduction Permit for the St, Paul Tape Plant, investment in the 

development of the proposed Emissions Tracking and Reporting 

System will significantly improve;current VOC emissions reporting 

by: 

* Calculating emissions on a daily rather than annual basis 

* Allowing the tracking of emissions to an individual production 

machine 

* Establishing the capability to predict daily emission levels 

based on production plans 

* Simplifying MPCA Verification and Audit Processes 

Figure 1 on the following page depicts the flow of logic proposed 

for the VOC Emissions Reporting System. A narrative description 

on how 3M would calculate daily emissions for the facility using 

the proposed system follows: 
P.10 

U t V 39dd 8 1=21 26. 2 a WW 

Proposed 

Solvent Emissions Reporting System 

LOGIC F 

i 

/sOLVENl 

/ LIST 

-

• 

r 

LOW 

^ • 

/PROOUCT\ 

/STRUCTURE5\ 

WHERE USED 

[LIST OF PRODUCTS TWAT 

USE THE SOLVENTS] 

' • 

1 (DATA 

TOTAL 

SOLVENT USAGE 

BY MACHINE 

' 

f " '^ 

1 

/ 

/ Ui>ALiz \ 

-/B Y MACHINE\ 

AVAILABLE 24-36hrs ArTER PRODUCTION] 

-

(AS: 

EMISSION RELATIONSHIPS 

(BASED on ENGINEERING PRINCIPALS) 

/ rviiNi x /FUGITIVEX 

/ SOURCES \ / SOURCES \ 

5UME 100% EVAPORATlONij (START W|TH AP*2 PARAMETERS] 

RE< 

r 

DAILY EMISSION RPTG 

X)VERY/OXIDATION PARAMETERS 

/ \ 

/ CONTROL \ 

/EFFICIENCYX 

TS!:..'^:' 
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LOGIC FLOW: 

Please refer to Figure 1. 

1) The process begins with a database that provides a list of 

VOC containing materials. The Solvent List. 

2) The program will search over 2000 existing and new electronic 

recipe files (the PRODUCT STRUCTURES, see Figure 2) to 

determine the intermediate and final products that contain 

any level of the VOC containing materials. The objective of 

this process is to create a list of potential products that 

are made up of the VOC containing materials (the WHERE USED, 

see Figure 3) . 

PRODUCT STRnf!«PtmES 

1) TAPE PRODUCT A 

BACKING B 

ADHESIVE C 

2) ADHESIVE C 

RAW MATERIAL D 

RAW MATERIAL E 

SOLVENT F 

1.0 

0.5 

0.3 

0.4 

0.3 

fffigRS USED 

SOLVENT F 

* ADHESIVE C 

* TAPE PRODUCT A 

Fig. 3: Ex. Where Used 

Where used list indicat** solvent F 

is a component in Adhesive C and 

Tape Product A thru Adhesive C 

Fig. Ex. Product Structures 

3) The WHERE USED list of potential products containing VOC 

materials is then used to select daily production records 

from existing production reporting systems (that have 

production data available 24-36 hrs after the actual 

production day) to determine the amount of solvent used by 

each piece of production equipment on that day. 

4) To determine the actual VOC emissions from each piece of 

production equipment the usage determined in step 3 above 

must be related to emissions generated by the equipment that 

produced the product. This relationship -will be determined 

from two databases (the EMISSION RELATIONSHIPS) that will 

contain emission parameters for: 1) any equipment connected 

to a point source emission stack (POINT SOURCE); and 2) all 

other production equipment (FUGITIVE SOURCES). 
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POINT SOURCE emissions will be calculated assuming 100% 

evaporation of the solvent. This is a conservative estimate 

which assumes none of the solvent(s) remains in the product. 

The AP42 Emission Parameters will be used for the FUGITIVE 

SOURCES calculations. (Initial "certification" of the 

emission parameters would have to be completed by-3M and the 

MPCA) . As periodic testing of these parameters is performed 

the database will be updated and the calculation results will 

be refined and "certified." 

5) To determine the level of VOC emissions actually released, 

the total created emissions calculated in the preceding step 

must be reduced by any recovery and/or destruction of the 

captured emissions. These calculations would be performed on 

a daily basis through parameters established for the capture 

efficiency of the emission collection systems and 

destruction/recovery efficiency of the control systems. 

6) The final output is a daily calculation of emissions 

generated by the St. Paul Tape facility. 3M proposes to 

retain these daily emission calculations and provide the MPCA 

with a quarterly report detailing the daily emissions for 

each quarter. Access to the reporting system and its outputs 

would be provided to monitoring agencies on an audit basis 

for validation and verification. 

Developed as a means to improve emission tracking and reporting 

under a Source-Wide Air Emissions Reduction Permit for 3M*s St. 

Paul Tape Plant, the proposed Emissions Tracking and Reporting 

System will significantly improve existing emissions reporting for 

our stationary source. 

f,OMPT,TANCE DEMONSTRATION AND ENFORCEABILITY 

Compliance demonstration is practical and simple with the 

emissions tracking system. By establishing a permit cap of 4500 -

tons per year of VOC emissions, the need (requirement) to operate 

the thermal oxidizer whenever the coating equipment is in 

operation (excluding breakdown and/or malfunction of the oxidizer 

system) is established. Verification that the thermal oxidizer 

has been in operation during coating can easily be accomplished by 

viewing the strip chart recorders in the thermal oxidizer control 

room. Any downtime of the thermal oxidizer system due to 

breakdown or malfunction of equipment would be reported to the i^ 

MPCA. * " A/' 

* > ' J> 
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Shorter-term emission limits such as tons per.quarter or tons per 

month, could also be established to increase assurances of, 

compliance with the source-wide" cap of 4500 tons per year provided 

these shorter-term limits reflect the plant's operating 

variability. 3M is soliciting constructive agency comments on how 

these compliance mechanisms should be structured. 

Once the emissions tracking system, including the data bases, has 

been "certified," the thermal oxidizers destruction efficiency and 

capture efficiency would have to be verified. 3M is proposing to 

varify the destruction efficiency through biennial stack tests, 

conducted in accordance with U.S.EPA/MPCA requirements. Periodic 

capture efficiency testing will also be done to verify the overall 

control efficiency of the systems. 

When this has all been completed, MPCA and U.S.EPA personnel can 

come into the source and.compare the annual emissions (and any 

other shorter-term emissions agreed to) against those contained in 

the Source-Wide Air Emission Reduction Permit for easy and 

practical enforcement of the permit conditions. 
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