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OAR Box 1790 

Prepped by Keeia Richards 

Document Number: 

206) ll-E-2 

Docket Number: 

A-90-37 

Printed 10/31/2008 12:43:16 PM Sheet 206 of 250 
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l-SK 

*< »&* V 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

JUN I 7 1993 

OFFICE OF 

AIR ANO RADIATION 

MEMORANDUM 

SUBJECT 

FROM: 

Applicability of New Source Review Circumvention 

Guidance to 3M - MaplewQQel, Minnesota 

:e Division 

John B. Rasnic, Director Sm^miM^^ 

Stationary Source Compliatlc* 

Office of Air Quality Planning and Standards 

TO: George T. Czerniak, Chief 

Air Enforcement Branch 

Region V 

This is in response to your memorandum dated March 16, 1992, 

requesting guidance on New Source Review (NSR) permitting for the 

Minnesota Mining and Manufacturing (3M) Center located in 

Maplewood, Minnesota. Specifically, you requested guidance on the 

applicability of the circumvention guidance to this source and 

other sources in similar situations. We also received from your 

staff more information about the modifications at 3M and we 

suggested that you issue a §114 request to the source for more 

information. In early November, we received a copy of the 

response to the §114 request dated October 30, 1992. We hope this 

memorandum provides sufficient guidance on permitting this source 

and other sources in similar situations. 

Background 

In your memorandum of March 16, 1992, you notified us that 

the 3M Center in Maplewood, Minnesota received four synthetic 

minor permits for modifications between October 1991 and March 

1992. The permits for the four modifications combined allow 

emission increases of 33.6 tons per year (tpy) of particulates, 

39.8 tpy of sulfur dioxide, 39.4 tpy of nitrogen dioxide, 22.0 tpy 

of carbon monoxide, and 119.2 tpy of volatile organic compounds. 

You learned during the Region's discussions with Minnesota that in 

18 months, the source received 12 minor permits, and applied for 

several- other minor permits. As a result, you indicated to the 

Minnesota Pollution Control Agency (MPCA) that 3M may be 

circumventing the Prevention of Significant Deterioration (PSD) 

regulations through these small projects. The MPCA, however, felt 

that these modifications were justified as separate modifications 

based on each 3M division pursuing its own research schedule. 

Primed on Recycled Papet 
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For Administrator's meeting with 3M scheduled for 9/10/93. 

Q. What is 3M's perspective of the Agency's new source review 

(NSR) rules? 

A. New major stationary sources of air pollution and major 

modifications to major stationary sources of air pollution are 

required by the Clean Air Act to obtain an air permit before 

commencing construction. The process is called new source review 

(NSR) and has major economic and environmental implications for 

large new sources of air pollution (e.g., new automobile or 

semiconductor assembly plants) and modifications of existing 

plants (e.g., expansion to an existing oil refinery). To obtain 

a major source NSR permit sources must apply advanced pollution 

controls, in clean air areas preform complex air quality modeling 

and other analyses, and in dirty areas secure emissions 

reductions at existing sources. 

In general, the NSR permitting process is often contentious 

and can take the better part of a year or longer. Industry's 

concern is that this inhibits their ability to quickly respond to 

changes in global market conditions. EPA has worked with 3M at 

their Saint Paul, Minnesota industrial adhesive tape plant 

facility to establish a mechanism (i.e., a plant wide 

applicability limit) which provides them with certainty and 

flexibility while avoiding costly permit delays. 3M has been 

pleased with the outcome and the with the Agency's willingness in 

working with them on this approach. They have discussed with us 

the potential application of this type of mechanism to some of 

their other facilities. 

On other hand, EPA is investigating 3M's Maplewood, Minnesota 

facility regarding possible circumvention of the NSR permitting 

requirements regarding the addition of numerous new units to the 

existing facility. A detailed discussion of this issue is 

contained in the attached memo.