3m’s experience with flexible air quality permits3m’s experience with flexible air quality...
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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
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1. The New Business Reality
2. 3M’s Flexible Permits
3. Improvements to Promote Flexible Permits
4. EPA-State Partnerships & Regulation Reform
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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
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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)
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• 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)
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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
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3M Menomonie, WI Facility
• > 700,000 sq. ft.
• > 800 employees
• Initial Flexible Permit: Dec. 2004
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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
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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
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s
Improvements to Promote
Flexible Permits
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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!
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2. Issue Flexible Permits as Quickly as Conventional
Permits
Improvements to Promote Flex. 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
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3. Institutionalize the Expertise for Issuing Flex. Permits
Improvements to Promote 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
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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
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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
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Thank You!