© 3m 2008. all rights reserved. innovations in permitting and flexible air permitting as well as...

© 3M 2008. All Rights Reserved.

Innovations in Permitting and Flexible Air Permitting as Well as Methods to Improve the Permitting Process

Mark Manninen, 3M Environmental Operations

New Jersey Clean Air Council 2010 Public Hearing

April 14, 2010

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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing

Overview of 3M Company Creating Flexibility within Existing Permits Innovative Flexible Permits

Agenda

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Founded in 1902 and headquartered in St. Paul, MN

2008 Information• Sales: $25.3 billion (>60% international)• R&D and Related Expenditures: $1.4 billion• Employees: 79,000

Providing over 50,000 products to multiple industries across the globe

3M Company Profile

80+ Permitted Facilities in 28 States80+ Permitted Facilities in 28 States

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Keeping Pace with Speed of Change Lean Manufacturing

Projects

Formulation Changes

Plant Consolidations

Fuel/Energy Reduction Projects

Shorter Notice Prior to Desired Construction Date

Shorter Notice Prior to Desired Construction Date

Average Permit Project Lead Time

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Low VOC Coating Example:

Regenerative Thermal Oxidizer BACT =

96% Overall Control of VOCs

4% VOC to Atmosphere

Creative Permit Language

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3M Innovative Flexible Permits

3M St. Paul Main – First Innovative Flexible Permit Issued in 1993

Current Flexible Permits 3M Brownwood (Texas) 3M Nevada (Missouri) 3M Menominee (Wisconsin)

US EPA Flex Permit Rule - Issued September 25, 2009

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Flexible Permit Basics

Title V Permit with additional provisions to allow for certain pre-approved changes in return for “beyond compliance” commitments

Prescriptive permit requirements address all applicable air regulations (MACT, NSPS, NAAQS, State Regs, etc.)

Pre-approved changes to be completed without traditional construction permit authorization and timeline

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Benefits of Flexible Permits

Allows Permittee to rapidly react to business needs Reduced administrative burden for agency and Permittee Provides Permittee with incentive to reduce environmental

footprint

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Case Study – 3M Menomonie Diverse facility

manufacturing products for >15 different 3M Divisions

Initial flexible permit issued in 2004 and renewed in 2008

Benefits

16 flexibility projects implemented since 2005 Significant time and resource savings for 3M and WDNR Environmentally beneficial projects and partnerships

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Case Study – 3M Menomonie Example of Title V Permit language additions required for

installation of several web coating lines

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Case Study – 3M Menomonie

VOC Emission Reductions

Actual VOC lb emissions vs. 1,000 lb or product output

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Future Need for Flexible Permitting

Reductions in both industry and agency resources will require more innovative permitting approaches

Economic uncertainties impact on the speed of business Great opportunity to promote voluntary environmental

programs

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Questions ?

© 3m 2008. all rights reserved. innovations in permitting and flexible air permitting as well as...

Documents

naem forum

flexible air

public hearing overview

public hearing questions

timeline slide

existing permits slide

environmental footprint

flexible permitting