Flexible Air Permitting and EPA's Proposed Rule—Briefing Sessions for Performance Track Participants

Pilot Flexible Air Permit Profile

Source: 3M Corporation
Facility Type: Tape manufacturer
Location: St. Paul, Minnesota

The Minnesota Pollution Control Agency (MPCA) and EPA worked with 3M Corporation to develop and issue one of the first flexible air permits in the country. The permit enabled the St. Paul Tape Plant to compete for production opportunities within a diverse global market of manufacturing corporations. The flexible permit ensured that all applicable regulatory requirements were addressed and created incentives for the company to lower the plant-wide emissions while reducing associated paperwork and administrative costs.

On March 4, 1993, 3M Corporation’s St. Paul Tape Plant received a flexible air operating permit (Permit no. 23GS-93-OT-1) that contained plant-wide emissions caps and advance approvals for certain defined categories of operational and equipment changes. The plant produces over 550 specialty tape products, with many having production lifetimes of only 6 to 9 months. Advance approval of certain operational and equipment changes by the permit gave 3M greater control and predictability in meeting market demands and improving production processes.

Tools & Methods Used in the Pilot Permit

Alternative Operating Scenarios (AOS) and Advanced Approvals	Approvals for specified categories of operational changes and other changes deemed to be “consistent with” the specified change categories. Changes included modifications to and relocations of coating equipment, ovens, including replacement of motors and drives.
Approved Replicable Methodologies (ARMs)	Replicable testing procedure enabling updates to capture and destruction efficiency parameters for pollution control devices without requiring permit modifications.
Plantwide emissions caps	Plant-wide emissions limits for VOC (4,596 tons/year; 30,600 lbs./day).
Pollution prevention (P2)	P2 not required under the plant permit, but encouraged by MPCA.
Implementation logs	3M was not required to submit a log – company was required to document AOS changes made each year in annual report.

Environmental Benefits and Pollution Prevention

Reduced allowable and actual air emissions. In 1988, the plant voluntarily installed pollution control equipment (i.e., thermal and catalytic oxidizers) to bring actual VOC emissions down from 10,600 tons per year (tpy) to 4,300 tpy. The flexible permit capped facility-wide VOC emissions to 4,283 tpy, and actual facility VOC emissions during the permit term dropped to under 1,000 tpy due to production decreases, increased utilization and capture by control equipment, and pollution prevention improvements.
Easier P2 implementation. Pollution prevention (P2) activities made during the permit term, such as upgrades to process control equipment, improved process yields, causing the amount of VOC emissions to drop. In addition, the flexibility of the St. Paul Tape Plant to absorb solvent-borne production activities from other plants enabled other 3M plants to shift production to processes based on solvent-less coatings.

Economic Competitiveness Benefits

Agile manufacturing. 3M was authorized in advance to make physical or operational changes in certain pre-defined categories, provided that the VOC emissions did not exceed stated limitations after the change was made. 3M noted that the permit has enabled the facility to make operational and equipment changes that improve efficiency and the company’s overall pollution prevention program.
Extending facility life. The St. Paul tape plant was one of the oldest facilities in 3M’s global network of production plants. The permit enabled 3M to undertake renovations to coating and other processes in the facility to extend the productive life of the plant.

Monitoring and Enforceability

Replicable monitoring and routine reporting. 3M tracked site-wide VOC emissions using a combination of material mass balance (based on chemical usage), continuous emissions monitoring, and parameter monitoring associated with the pollution control equipment. MPCA reported that the monthly reports of daily and rolling annual VOC emissions required of 3M provide the agency and the public with a better picture of overall facility emissions than would be received under a conventional permit.

Corporate and Government Efficiency

Compliance burden reduction. During the permit term, 3M made 34 equipment and operational changes that utilized the advance approval conditions of the flexible permit. 3M estimated that 15-20 of these changes would likely have required case-by-case permitting actions. MPCA estimates that the 3M flexible permit eliminated the need for about 20 case-by-case permitting actions, saving the agency approximately $45,000 and reducing the agency’s permitting backlog.
Paperwork and backlog reduction. Given that the MPCA had a significant permitting backlog at the time, under a conventional permit (without advance approved changes) each of these changes could have experienced up to a 9-month delay before receiving agency approval. The permit also contained replicable testing procedures that enabled 3M to update control equipment monitoring parameters without requiring time-consuming permit modifications, provided that MPCA approved the source performance test results.

Public Response

Conventional public comment process. MPCA held an open public hearing following the public comment period on the draft flexible permit. No comments were received by MPCA related to the permit. While there were a few odor complaints from facility neighbors during the permit term that are not related to flexibility provisions of the permit–complaints dropped off in subsequent years as the facility phased out an odor-causing solvent.