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New Jersey Clean Air Council 2010 Public Hearing April 14, 2010

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. Agenda. Overview of 3M Company

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New Jersey Clean Air Council 2010 Public Hearing April 14, 2010

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  1. Innovations in Permitting and Flexible Air Permitting as Well as Methods to Improve the Permitting ProcessMark Manninen, 3M Environmental Operations New Jersey Clean Air Council 2010 Public Hearing April 14, 2010

  2. Agenda • Overview of 3M Company • Creating Flexibility within Existing Permits • Innovative Flexible Permits

  3. 3M Company Profile • 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 80+ Permitted Facilities in 28 States

  4. Keeping Pace with Speed of Change Average Permit Project Lead Time • Lean Manufacturing Projects • Formulation Changes • Plant Consolidations • Fuel/Energy Reduction Projects Shorter Notice Prior to Desired Construction Date

  5. Creative Permit Language Low VOC Coating Example: Regenerative Thermal Oxidizer BACT = 96% Overall Control of VOCs 4% VOC to Atmosphere

  6. 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

  7. 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

  8. 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

  9. 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

  10. Case Study – 3M Menomonie • Example of Title V Permit language additions required for installation of several web coating lines

  11. Case Study – 3M Menomonie VOC Emission Reductions Actual VOC lb emissions vs. 1,000 lb or product output

  12. 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

  13. Questions ?

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