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OAR Box 1790 

Prepped by Keeia Richards 

Document Number: 

205) ll-E-1 

Docket Number: 

A-90-37 

Printed 10/31/2008 12:43:16 PM Sheet 205 of 250 
200*39d d M9 0 98 8 21 8 

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ATIN I'M) .STATES ENvTRCMffifcliaL H»5J133LZL,

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PJBSTON V 

CftTE: MAR 171992 

SUBJECT: Maetiisg with tlie 3K Company to Discuss an Emissions cap Proposal 

PfiCH: William L. MacDowell, Chief •//|L/3(U I tf4r«$\*.s*Q0 

Regulation Developr^t Section KW**^' ^ 

Air Enforcement .Branch 

TO: Piles 

On .March 6, 1992, representatives of the United States Environmental 

Protection .agency (U.S. EPA) met with i^presentatives of the 3M company (3M) 

and the Minnesota Pollution Control Agency (MPCA) in Chicago. The purpo.se of 

this meeting was to provide 3H with an opportunity to present its proposal to 

use a facility-wide pmisslons cap on volatile organic compound (VOC) emissions 

at the St* Paul Tape Manufaxirturing .Division plant, and to answer any questions 

U.S. EPA had in regard to the proposal. The following provides a suwnary of 

the major topics discussed at this meetix*?. 

gource focKqround 

The St. Paul Tape ftonufacturing Division plant, located about 3 miles from 

3M*s research facility, is 3M*s original tape plant. The p.lant now uses 17 of 

the original 21 ovens to produce approximately 400 different types of 

specialty tapes, usually in the high performance field. In 1990 two tih^wiwi 

oxidizers were installed voluntarily as part of 3M's pollution prevention Plus 

Program. The exhaust from 16 of the ovens go to one large oxidizer, and the 

other oxidizer is for one unique oven. 3M estimates the capture efficiency to 

be 68 percent. 

Over the next five years 3M intends to maJce .several modifications at this 

facility. These are all renewal and process improvement projects and will be 

modifications to existing equipment. If the traditional method of permitting 

were used for these modifications, 3M estimates that it would take 3 to 8 

permit applications. 

Proposal 

3M is pixjposixaj to establish an emissions limit of 4500 tons/year on VOC 

emisSaions frcm this facility, which is substantially lower than its potential 

to emit (65,000 tons/year) and its actual emissions prior to control 

(10,600 tons/year, 1988-1989). This emissions cap would require the 

continuous use of the thermal oxidizers installed as part of 3M's Pollution 

Prevention Plus Program and is approximately equal to emissions from the 

facility after installation of the thermal oxidizers (4453 tons/year, 1991). 

In addition, an emissions cap would require the installation and operation of 

an extensive eadssions tracking system which .includes all equipnent at the 

facility. 3M sees the following benefits from this approach to permitting: 
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1. Provides a permit for the entire facility. 

2. Requires operation of the thermal oxidizers to meet limit. 

3. Provides a cap on anissions when current regulations would allow 

substantial increases through netting. 

4. Eliminates Prevention of Significant Deterioration (PSD) 

permitting concerns (definition of modification, time for permit 

review, etc.). 

5. Eliminates permit modifications unless 3M wishes to increase the 

cap at a later date. 

6. Provides an extensive oni reigns tracking system for the entire 

facility. 

7. Reduces resource demand for 3H, MPCA, and U.S. EPA. 

3M has proposed three options for permitting future modifications to the 

source. These options .are as follows: 

1. 40 CER 52.21(b) (21) (ii) requires the establishment of a 

••representative" actual baseline, usually the two years which 

precede the date of the change; however, this definition also 

provides that "the Administrator shall allow the use of a 

different time period upon a determination that it is more 

representative of normal source operation." 3H wants to set its 

actual eminsicnaS equal to 4500 tons/year VOC for the life of the 

permit. This number is lower than the two year average would be 

for a modification applied for at this time. <•' 3M would also like 

to set a cap on future emissions for the source at 4500 tons/year. 

Therefore, actual emissions would equal potential emissions from 

the facility after aay modification, 

2. The second option is similar to the first, but uses allowable 

emissions. 40 era 52.21(b) (21) (iii) .states "the Administrator may 

presume that source-specific allowable emissions for the unit are 

equivalent to the actual emissions of the unit." Therefore actual 

would equal allowable emissions, 4500 tons/year, and the potential 

would be established through the <mission3 cap of 4500 tons/year. 

Under these options 3M could make .sny modification to the source it wanted as 

long as emissions did not exceed 4500 tons/year. 

3. This option would set the contemporaneous time period, and use the 

traditional netting out process over a longer period of time. 

This would allow 3H to use the emissions decreases from the 

installation of the thermal oxidizer for two years longer than 

would normally be allowed, zn addition, 3H wants a streamlined 

method of reviewing modifications and netting calculations to 

decrease the time for review. 

For the 4500 ton/year cap, 3M would be willing to use a 365 day rolling 

average. 

Region V will discuss these options with Headquarters to determine if any are 

feasible, or if there is soma way to altar these options to make them suitable 

to HPCA, U.S. EPA, .and 3M.