3M’s Experience with Flexible Air Quality Permits3M’s Experience with Flexible Air Quality Permits NACAA Fall Membership Meeting John Metzger, P.E. 3M Sr. Envir. Specialist

1 . All Rights Reserved. 15 September 2017 © 3M 3M Confidential.

3M’s Experience with

Flexible Air Quality

Permits NACAA Fall Membership Meeting

John Metzger, P.E.

3M Sr. Envir. Specialist [email protected]

Sep. 25, 2017


1. The New Business Reality

2. 3M’s Flexible Permits

3. Improvements to Promote Flexible Permits

4. EPA-State Partnerships & Regulation Reform


The New Business Reality

A New Paradigm:

• From: Permits that are a precondition of manufacturing

• To: Permits that reflect the current business reality by

facilitating rapid manufacturing changes and speed to market

Flexible Permits are a 3M Business Asset:

• Enable rapid manufacturing changes responsive to changes in

the marketplace and R&D advances

• Provide certainty of outcomes

And ensure compliance with all applicable regulations


What is a Flexible Permit?

• Advance approval of categories of changes, working together with …

• A PAL, a facility-wide emissions cap, or other mechanism that ensures no facility

changes are subject to major NSR/PSD — that is, so that facility changes are subject

mainly to the state’s minor NSR program (e.g., including air toxics), federal technology

standards (MACT/NSPS), etc.

• And ensures compliance with all applicable regulations

“[C]ontains one or more approaches that allow the source, under protection of the permit

shield, to make certain types or categories of physical and/or operational changes without

further review or approval of the individual changes by the permitting authority as they

subsequently occur.” 74 Fed. Reg. 51,419 (Oct. 6, 2009)


• Dates to early 1990s

• St. Paul, MN

• Weatherford, OK

• 3M provided input on EPA’s 2009 Flexible Air Permitting Rule ― 3M-related (includes

Imation) flexible permits are cited in the preamble [74 Fed. Reg. 51,418 (Oct. 6, 2009)]

• 3M participated in EPA OECA’s independent review of flexible permits (2001)

3M’s Experience with Flexible

Permits

2 permits

• 3M flexible permits that are active or under review (in 4 states)


Example

s Plant A ― No Flexible permit

• 3M developed a product that would bridge between the industry’s current and

rapidly oncoming new technologies

• Projected to provide strong sales, but for no more than about 10–13 months

• A permit to modify the designated manufacturing line would require 3–5 months

• Result: Project dropped

Plant B – Flexible Permit

• Problem: Relocate a manufacturing line ASAP from a 3M facility that was being

closed

• Solution: Relocated to Plant B because it could be done immediately, and all

requirements were known in advance


3M Menomonie, WI Facility

• > 700,000 sq. ft.

• > 800 employees

• Initial Flexible Permit: Dec. 2004


3M Menomonie, WI

Facility

Films for

brightness

enhancement

& privacy

High gloss reflective

materials

Specialty tapes & materials

NextelTM

Ceramic Textiles

Fuel Cell Technology

Products: many markets, involving~ 60%

of 3M’s technology platforms

Dual

LockTM


3M Menomonie, WI • 6 plant expansions

• > 20 advance-approved projects,

saving >70 months start-up time

• > 50% increase in employment

Flexible Permit issue Dec. 2004


s

Improvements to Promote

Flexible Permits


1. Flexible Permits Need to Move Beyond Champion-driven

Improvements to Promote Flex. Permits

• Move from champion-based permits, to permits driven by and encouraged

jointly by permitting authorities and EPA regional offices

• Each of 3M’s flexible permits (except 1) has had a clear, non-3M champion.

• TX, OK, MO: OAQPS

• WI: a WI DNR program lead outside of the permitting program

The champion was a clear driver of success, challenging misgivings by the

permitting authority or the corresponding EPA regional office

Suggest: An EPA-State partnership can promote flexible permits in the future!


2. Issue Flexible Permits as Quickly as Conventional

Permits


• Timeline and commitment of resources is a key barrier

• Each of 3M’s flexible permits has required 2 years or more to put in place

• Flexible permits can become a part of the norm

Suggest: An EPA-State partnership — including resources and support from

EPA, such as templates, examples of successful permits, direct problem

solving with permitting authorities — driving towards putting flexible permits in

place more quickly


3. Institutionalize the Expertise for Issuing Flex. Permits


• Most of EPA’s staff (M. Trutna, D. Dellarco, D. Beck, etc.) that worked

with 3M and state permitting authorities have retired or moved on to other

assignments

• Same for staff of state permitting authorities

• Previously-issued flexible permits that come up for renewal face

questions from state and EPA (regional office) staff that are generally

new to the subject

Suggest: Build expertise for flexible permits within EPA (OAQPS and

regional offices) and within state permitting authorities — especially by

issuing more flexible permits


Revitalize/Refocus a Program Dating from the 1990’s

• Move flexible permits towards an EPA-State partnership

• EPA revitalize, refocus & improve flexible permits as an aspect of Regulatory

Reform (does not require new or revision of existing federal rules)

• Provide expertise on federal technology standards, PALs, etc. in flexible

permits

• Provide training to state permitting authorities (especially states that have

not previously issued flex. permits) and EPA regional offices

• Set the tone & provide encouragement for issuance of flexible permits

• Provide advocacy & suggestions on addressing minor NSR program

requirements in flex. permits – e.g., state air toxics

• Provide guidance, templates, examples, success stories, etc. of flexible

permits; providing direct problem-solving on individual permit projects


Conclusion

• 3M is actively working with several state permitting authorities to

renew flexible permits—we thank these permitting authorities for their

past and continuing efforts and ask for their continuing support

• 3M is ready to provide any support to EPA on flexible permits that

would help move the subject forward


Thank You!

Documents

3M’s Experience with Flexible Air Quality Permits3M’s Experience with Flexible Air Quality Permits NACAA Fall Membership Meeting John Metzger, P.E. 3M Sr. Envir. Specialist