© 3m 2008. all rights reserved. innovations in permitting and flexible air permitting as well as...
TRANSCRIPT
© 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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
Low VOC Coating Example:
Regenerative Thermal Oxidizer BACT =
96% Overall Control of VOCs
4% VOC to Atmosphere
Creative Permit Language
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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
Case Study – 3M Menomonie Example of Title V Permit language additions required for
installation of several web coating lines
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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
Case Study – 3M Menomonie
VOC Emission Reductions
Actual VOC lb emissions vs. 1,000 lb or product output
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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
© 3M 2007. All Rights Reserved.
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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2009 NAEM Forum – 3M Employee EngagementNew Jersey Clean Air Council – 2010 Public Hearing
Questions ?