HomeMy WebLinkAbout2010-08-11 PACKET 08.A.REQUEST OF CITY COUNCIL ACTION COUNCIL AGENDA
MEETING ITEM #
DATE 8/11/2010
Administration
ORIGINATING DEPARTMENT
Ryan Schroeder
DEPARTMENT HEAD
COUNCIL ACTION REQUEST
Consider adopting a resolution approving the Air Monitoring Agreement with 3M Company.
STAFF RECOMMENDATION
Adopt the resolution.
BUDGET IMPLICATION
BUDGETED AMOUNT ACTUAL AMOUNT
SUPPORTING DOCUMENTS
® MEMO /LETTER: Memo from Ryan Schroeder.
® RESOLUTION: Draft.
❑ ORDINANCE:
❑ ENGINEERING RECOMMENDATION:
❑ LEGAL RECOMMENDATION:
® OTHER: Attachments.
ADMINISTRATORS COMMENTS
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DocumenQ
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To: Honorable Mayor and City Council Members
From: Ryan R. Schroeder, City Administrator
Date: August 5, 2010
Subject: 3M Incinerator Air Monitoring
For the past several months representatives from the 3M Company, and the City of Cottage
Grove have been working toward an agreement regarding ambient air monitoring of heavy
metals„ particulate (TSP), and volatile organic compound (VOC) emissions related to the 3M
Corporate Incinerator at the 3M Cottage Grove plant site. The City has made attempts to
become one of the 54 sites monitored within the Minnesota Pollution Control Agency (MPCA)
annual air monitoring network plan for Minnesota but, to date, has been unsuccessful in doing
so. Absent inclusion in that network plan, and in reaction to an upcoming Incinerator permit
review by the MPCA, the City and 3M have worked toward an agreement to provide for a short
term project that has parameters similar to the MPCA network plan.
The proposed plan is enclosed for Council review and consideration. In summary, the plan
proposes that the City and 3M jointly establish an air monitoring station in a location jointly
determined on the 3M Cottage Grove plant site. The station would be built to provide for the
metals, TSP, and VOC monitoring on a 12 day cycle with 24 hour monitoring during each of
those 12 days for up to 3 years. 3M, under the agreement, would provide funds to the City to
pay for the metals and TSP monitoring. The City would fund the VOC monitoring. Analysis of
the monitoring results would be provided by the City's environmental consultant. The measure
of analysis would be one standard deviation above the averaged results of the MPCA network
plan. Costs for the City portion of this project would be from the budget provided to the
Environmental Commission within each of the next three budget cycles. Monitoring is
proposed to begin shortly after approval of the monitoring agreement. It is intended that this
monitoring be put in place prior to MPCA consideration of the Incinerator emissions permit for
the next five year permit period. This timing would allow for analysis during the existing
condition of inputs into the Incinerator in addition to any change in inputs that result within the
next emissions permit.
Staff believes that the proposed agreement is responsive to previously stated Council
concerns regarding future emissions from the 3M Corporate Incinerator.
1. Council Action: By motion approve resolution 2010 -xx approving the Air Monitoring
agreement
RESOLUTION NO. 2010 -XX
WHEREAS, the 3M Company and the City of Cottage Grove have worked
jointly to address concerns about potential air emissions from the 3M Corporate
Incinerator as related to incinerator permit modifications located at the 3M
Cottage Grove plant site, and
WHEREAS, the 3M Company is required by the Minnesota Pollution
Control Agency (MPCA) to submit for an operations permit for operation of the
3M Corporate Incinerator, and
WHEREAS, the City of Cottage Grove is desirous of providing an
environment conducive to business growth and expansion while ensuring limited
impacts of business expansion and mitigation of any negative impacts, and
WHEREAS, the 3M Company is committed to continuing its record of
positive environmental stewardship going forward, and
WHEREAS, both the 3M Company and the City of Cottage Grove wish to
cooperate to ameliorate concerns regarding Incinerator air emissions permitting
going forward and jointly support the program, process, and intent outlined
within the MOU dated August 11, 2010 in satisfaction of those concerns;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF
THE CITY OF COTTAGE GROVE that the memorandum of understanding
between the 3M Company and the City of Cottage Grove dated July 7, 2010 is
hereby adopted.
Passed this 7th day of July 2010.
Myron Bailey, Mayor
Attest:
Caron M. Stransky, City Clerk
Memorandum of Understanding between the 3M Company
and the City of Cottage Grove in Response to
Pending 3M Incinerator Emissions Permit Renewal Request
Whereas in February, 2009, the 3M Company informed the City of Cottage Grove of an
intent to pursue non -3M wastes as a source material to fuel the 3M Corporate Incinerator at
the 3M Cottage Grove plant; and
Whereas, in response to a request by the City, 3M Company delayed a permit request
to the Minnesota Pollution Control Agency (MPCA) to allow for the creation of a study group
(Environmental Task Force) to evaluate impacts upon the environment and community of the
request; and
Whereas, on October 27, 2009, after said study, the Environmental Task Force
recommended permit requirements to address aspects of its analysis; and
Whereas, on November 4, 2009, the Cottage Grove City Council adopted the following
findings of their Environmental Task Force for transmittal to the MPCA, requesting that the
permit include:
1) Commercial Incineration A condition that prohibits commercial incineration at the
facility, defined as 3M accepting payment or other compensation for burning non -
3M waste. 3M voluntarily agrees to such condition.
2) Non -3M Wastes Allowed A condition that 3M may accept only bulk wastes with
high BTU content from non -3M wastes. All non -3M wastes must have one of the
following waste codes listed in the hazardous waste manifest: F001, F002, F003,
F005, D001, and those related to #4 below. 3M voluntarily agrees to such
condition.
3) Limits on Non -3M Wastes A condition that establishes a maximum limit of non -3M
wastes of 400,000 million BTU per year burned at the incinerator from sources
within the United States. 3M voluntarily agrees to such condition.
4) Law Enforcement Materials A condition that law enforcement waste may be
accepted only from Minnesota law enforcement agencies for processing at the
incinerator. 3M voluntarily agrees to such condition; and
Whereas, the City has also made the following requests of the MPCA:
1) Risk Assessment That with the 2010 permit renewal, an update shall be prepared
of the 2004 Human Health and Ecological Risk Assessment for the incinerator.
2) Incinerator Inspections. That their inspections of the 3M Corporate Incinerator be
conducted in a more random and unannounced nature; and
Whereas, to address concerns in the community regarding emissions, the City has
requested to install an ambient air monitor on the 3M Cottage Grove plant site. The purpose of
this air monitor is to assess suspended particulate matter (TSP) and heavy metal emissions
from the 3M Cottage Grove incinerator and to provide comparisons with rolling annual average
results collected by the MPCA in monitors throughout the Twin Cities Metropolitan Area and
National or Minnesota Ambient Air Quality Primary Standards as evaluation standards.
Now therefore be it agreed by the City Council of the City of Cottage Grove and the 3M
Company that:
1. 3M Cottage Grove and the City of Cottage Grove will construct an air monitoring
station to include a platform, security fencing, and aggregate base material at a
location on the 3M Cottage Grove plant site as determined by mutual agreement
of the City's environmental consultant, SEH Engineering, and 3M Company.
2. 3M agrees to provide access to the monitoring station for data collection,
monitoring station maintenance and calibration to the environmental consultant
performing the study.
3. 3M agrees to pay for installation of the air monitoring station, set -up and
calibration of equipment in the amount of $16,400. This monitoring equipment
may also be used to facilitate VOC monitoring funded by the City.
4. 3M authorizes the City's environmental consultant to operate said monitoring
station for a period of up to three years from the date of installation, estimated at
August 1, 2010, through July 31, 2013.
5. 3M agrees to provide funding to the City for this independent monitoring of TSP
& heavy metals sampling & analysis:
i. August 1, 2010 through July 31, 2011 - $60,000
ii. August 1, 2011 through July 31, 2012 - $60,000,
iii. August 1, 2012 through July 31, 2013 - $60,000, if needed
Monitoring data will be provided by the environmental consultant to the City, 3M
and the MPCA and evaluated by comparison to annual average air quality results
within the MPCA monitoring program for the metro area. Monitoring beyond July
31, 2012 will be determined by the City in consultation with 3M, based upon
results in comparison to the MPCA monitoring program. The City will consider
any annual average data from the monitor to be acceptable which is less than, or
no more than one standard deviation greater than, the average annual data from
the MPCA monitors.
Page 2 of 3
Terms of this memorandum agreed to this date of 2010
Myron Bailey
Mayor, City of Cottage Grove
Vickie Batroot
Site Director, 3M Cottage Grove
Page 3 of 3
August 4, 2010 Mayor Opening Remarks
Good Evening. I am Mayor Myron Bailey, and on behalf of the City Council I
would like to welcome you to the August 4, 2010 City Council meeting. This is a
regular meeting of the City Council. However, we are having the meeting at this
location because we thought the number of persons interested in this issue would
be greater than the capacity of our City Hall.
We only have one item on the agenda this evening. That item is to provide
members of the community an opportunity to ask whatever questions you may
have regarding the 3M Corporate Incinerator. As your Mayor, my intent tonight is
to increase your knowledge of the incinerator, history, and impacts. Tonight is not
about any other topic and we will not be addressing comments on any other topic
outside of the 3M Corporate Incinerator.
As many of you may know, we have been working with the 3M Company for the
past eighteen months on their proposal to burn non -31M owned wastes in the
Incinerator. There have been both Council and citizen concerns expressed
regarding that proposal and both 3M and the City Council take those concerns
seriously. We have come up with a solution, I believe, to many of those concerns.
We have been in discussions with 3M over the past few months to establish an
Ambient Air Quality Monitoring Station at or near the 3M plant site. I am pleased
to be able to inform you that we have achieved tentative agreement with 3M on an
Air Monitoring Station for Heavy Metals, Particulates and VOC's (volatile organic
compounds). What this means is that 3M has committed to the agreement we
have put in front of them. I am recommending to the City Council that we approve
this agreement. I am recommending approval because this Air Quality Monitoring
will create a benchmark against which future changes in air quality may be
measured and it allows us to compare the air quality near 3M Cottage Grove with
that of the rest of the metro area. It should be noted that based on information
from air quality reports it is expected that the air in Cottage Grove will be found to
be cleaner than that elsewhere in the Twin Cities.
If air quality does not meet PCA and EPA standards we would address that with
the MPCA, Department of Health, 3M and our consultant. We have studied the
PCA air monitoring program. We have found that the Twin Cities is home to many
manufacturing facilities with emissions outputs much higher than those from
manufacturers calling Cottage Grove their home. I will be asking our
Environmental Commission for their thoughts and recommendations regarding
these emissions from external sources.
As I mentioned earlier, this meeting provides an opportunity to share information
and to hear the facts of the operations permit at the 3M Incinerator. We have
structured this meeting to allow everyone present to ask their questions and to get
answers from our panel experts. These experts are:
1. Representing the City is our Environmental Consultant, Mr. Tom Henning
from the SEH Engineering Firm and Corrine Heine, our City Attorney from
the Kennedy & Graven law firm.
2. Representing the Minnesota Pollution Control Agency is Mike Sandusky, the
Director of Environmental Analysis and Outcomes and Frank Kohlasch,
Manager of the Air Assessment and Environmental Data Management
Section.
1 sincerely thank all of you who have agreed to help us this evening by being
members of this panel. 1 would also like to thank our Legislative Delegation and
the County for being here. I'd like to welcome Senator Katie Sieben,
Representative Denny McNamera, Representative Karla Bigham, and County
Commissioner Myra Peterson. And, of course, with me at the table is the Cottage
Grove City Council.
Finally, I wish to pass along to you that we appreciate the level of interest you all
have taken regarding the environment in Cottage Grove. In large part it is due to
this interest on your part that we now have an Environmental Commission to study
issues such as what we have before us this evening.
When you came in this evening you had the opportunity to view some of the data
that relates to this topic out in the hall. Hopefully, some of that was helpful to you.
You can also see that to my is a table with City staff persons with index
cards and pencils. To make the best use of everyone's time we ask that you
provide any questions you might have on these index cards. Our staff will get
those questions to me and as the moderator for this evening i will address your
questions to the appropriate panelist. If there are questions for which our
panelists are not able to provide a response this evening we will provide a
subsequent response to the best of our ability.
I have just a few quick comments on the issue before us.
1. 3M Cottage Grove has been a member of our community since 1948
2. The Corporate Incinerator was initially constructed in 1971
3. The Incinerator was reconstructed improving its efficiency and emissions
handling in 1999 -2001
4. Early in 2009 3M alerted the City of its intent to seek an amendment to its
Incinerator operations permit to allow for fuel sources from non -31M owned
solvents
5. Our Environmental Task Force was created and studied this issue for 3
months making a recommendation to the City Council in October 2009
6. In November 2009 the City Council adopted those recommendations which
are intended to be comments to the MPCA as that Agency considers any
permit modifications
7. Subsequent to that Council action we began working with 3M on Ambient Air
Monitoring. I intend to introduce the Monitoring Agreement to the City
Council at the August 11 City Council meeting. I am recommending
adoption of that agreement. I would request that any questions you have
about that Monitoring agreement be asked this evening.
In order to perhaps frame the issue a bit further I will offer each of the panelists
the opportunity to comment for 3 to 4 minutes. I should mention that while the
MPCA has agreed to participate on this panel they have informed me that their
comments will be limited to the general conditions of the 3M Incinerator
Operations permits and the general permitting process. They will describe the
future permitting milestones and opportunities for public input and comment.
I'd first ask MPCA Director Mike Sandusky for a few additional comments.....
Next, I'll call on our Environmental Consultant Tom Henning. Anything to add at
this point Tom ?...
Finally, I'd ask if our City Attorney, Corrine Heine, would like to add anything at
this time....
OK, now it's time for questions from the Public. We have some that we had
received in advance of the meeting which I'll start with. As I do that, however, I'd
ask again that if you have any questions you would like to add or ask please get
them to our staff over here.
Ok, first question.....
3M Statement
Cottage Grove City Council Meeting
August 4, 2010
3M appreciates this opportunity to provide comments regarding 3M's proposal to use
supplemental fuel sources for our corporate incinerator at 3M Cottage Grove.
For the last 16 months this proposal has been discussed and debated at numerous public
meetings — first at the environmental task force and then at several city council meetings.
Each public forum has enabled residents to provide comments and meaningful input.
Throughout this period, 3M has not only respected the process but have listened carefully
to resident input. Through Mayor Bailey's leadership, we are now at a point on this
issue where both 3M and the City of Cottage Grove are ready to move forward.
Both sides have agreed to an air monitoring program that we hope will bring peace of
mind to the residents of Cottage Grove. We are confident the data will show the 3M
Cottage Grove incinerator does not impact our air quality.
There is no question that emotions on this proposal have run deep at times. After
learning there were concerns in April of 2009, 3M made the decision to postpone the
regulatory process at the MPCA so that any member of the community, if they desired,
could participate in the city council - established process of an environmental task force to
study our proposal.
During the task force process, input from the community was provided and 3M
responded by making changes to its draft permit.
Based on community input, 3M has:
• Included language in the draft permit that prevents the incinerator from becoming a
commercial operation;
• Included limits on the volume of outside waste that can be brought -in;
• Delineated the types of waste that can be used;
• Agreed to provide annual emission reports to the city of Cottage Grove.
Outside of the permit, and in direct negotiation with the Mayor and members of the city
council, 3M will fund an air monitoring program to sample heavy metal emissions for
three years. We are confident the data from this program will confirm the incinerator at
3M Cottage Grove does not negatively impact our community's air quality.
Even with the proposed air monitoring agreement between 3M and the city, the public
participation process on this issue has not concluded.
The MPCA has indicated there will additional opportunities for public comment after our
permit is published. Interested parties will also be able to submit written comments in
addition to oral statements at any of the MPCA venues.
Throughout this process, 3M's words and actions have shown a deep respect for the
Mayor, City Council and residents of Cottage Grove. This respect will continue.
3M thanks Mayor Bailey for his leadership and commitment to reach a compromise on an
issue that at times seemed impassable and we look forward to partnering with the city on
other matters.
2
NMR71-7 • •:
Incinerator ! ! E
April 2, 2009 - Incinerator Open House Meeting 3M holds open house at Youth
Services Bureau offices to provide information on incinerator proposal. Meeting
notice published in the March 26, 2009 issue of the South Washington County
Bulletin.
May 5, 2009 - City Council Meetinq Council considered a resolution on
proposed modification to incinerator permit.
May 20, 2009 — City Council Meeting Council considers a revised resolution on
proposed modification to incinerator permit.
June 3, 2009 — City Council Meeting Council establishes Environmental Task
Force to study the proposed permit modification to the 3M Incinerator.
July 1, 2009 — City Council Meeting Council considers appointments to the
Environmental Task Force.
July 15, 2009 — City Council Meeting Council appoints members of the
Environmental Task Force.
August 5, 2009 — City Council Meeting Council approves contract with SHE, Inc.
to provide consulting services for review of proposed 3M Incinerator permit
modification.
August 5 2009 — Environmental Task Force Meeting Task Force reviews
information on 3M Incinerator and tours incinerator.
August 19 2009 — Environmental Task Force Meeting Task Force reviews
information on 3M Incinerator.
September 9 2009 - Environmental Task Force Meeting Task Force reviews
information on 3M Incinerator.
September 2009 Issue - Cottage Grove Reports Includes notice on Public
Forum on 3M Incinerator proposal.
September 23 — Environmental Task Force Meeting Public Forum Task Force
hold public forum at which 12 speakers provide testimony regarding the
proposed modification to the permit for the 3M Incinerator.
October 14, 2010 — Environmental Task Force Meeting Task Force reviews
emissions data from 3M Incinerator and considers testimony received at
September 23 Public Forum.
October 28, 2010 — Environmental Task Force Meeting Task Force adopts
report on 3M Incinerator to City Council which included recommended comments
on proposed modification to permit.
September 23, 2009 - Environmental Task Force Task Force held a public
forum on the incinerator proposal. Twelve speakers address the Task Force.
November 4 2009 — City Council Meeting Council reviews Environmental Task
Force report on incinerator and approves resolution on City comments to MPCA
on incinerator permit.
January 25 2010 — Planning Commission Meeting Commission holds a public
hearing on a Zoning Code amendment which prohibits commercial incinerators.
Notice of Public Hearing was printed in South Washington County Bulletin on
January 13, 2010.
February 17. 2010. City Council Meeting Council adopts Zoning Code
amendment prohibiting commercial incineration.
The meetings listed above do not include discussions of the proposed 3M
Incinerator permit modification at the Open Forum section of City Council
meetings.
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Report on cancer occurrence in Washington, Dakota counties shows rates fall within expected rang... Page 1 of 3
Minnesota Department of Health
June 7, 2007
Contact information
Report on cancer occurrence in Washington, Dakota counties shows
rates fall within expected ranges
Analysis undertaken in response to health concerns from PFC contamination
of area drinking water
Overall cancer rates in Washington and Dakota counties are very similar to the rest of
the state, even slightly lower, according to a new report released today by the
Minnesota Department of Health (MDH). In addition, the rates and types of cancers
that occurred within specific communities in those two counties were generally on a par
with other communities in the metropolitan area, the report says.
The analysis of data from the Minnesota Cancer Surveillance System (MCSS) was
undertaken in response to concerns expressed by area residents and elected officials
over people's exposure to perfluorochemicals (PFCs) in their drinking water. Some
communities in the area have groundwater concentrations that exceed MDH health
based values for certain PFC - family compounds, while other communities have levels
that are below HBV but still high enough that some residents are concerned.
Studies in laboratory animals indicate that at higher doses, PFCs may interfere with
liver and thyroid function and may cause developmental effects. Research to date has
shown no direct evidence that PFCs cause health problems in humans. At public
meetings hosted by MDH and other state agencies, some area residents have
questioned whether specific incidents of cancer or other illnesses are related to their
exposures to PFCs. In general, the presence of PFCs has led to concerns among
residents of Dakota and Washington counties about whether community cancer rates
are unusually high in communities where PFCs have been detected.
"Given the level of concern, we felt it was important to address public concerns by
examining cancer rates in these counties," said Dr. Alan Bender, manager of the
Chronic Disease and Environmental Epidemiology Section of MDH. "While this type of
analysis of cancer data cannot and does not address the question of whether PFCs can
be linked to cancer or other health effects in humans, this report can be very helpful in
http: / /www.health.state.mn.us /news /pressrel /cancer060707.html 8/4/2010
Report on cancer occurrence in Washington, Dakota counties shows rates fall within expected rang... Page 2 of 3
informing the public as to the actual occurrence of cancers in their communities."
The report provides detailed profiles of cancer rates among residents of Dakota and
Washington Counties. Using MCSS data for the 15 -year period 1988 -2002, it examined
county -wide cancer rates for all cancers combined and for each of about 25 of the most
frequent types of cancer, including liver and thyroid. In addition, analyses were also
conducted to examine incidence rates for selected (16) cancers for specific
communities, (by zip code), within each county. For that analysis, data from 1996-
2004 was used, largely due to population growth and limitations on community census
data.
In Washington County, there were 4,397 new cancers diagnosed among males,
compared to 4,549 that would be expected for this group, a significant 3 percent
deficit. Among females, there were 4,263 cancers diagnosed, nearly identical to the
4,261 expected.
In Dakota County, there were 7,479 new cancers diagnosed in males, compared to
7,702 that would be expected for this group, a significant 3 percent deficit. Among
females, 7,583 cancers were diagnosed and 7,440 cancers were expected, an excess
that was not statistically significant, according to analysts.
When the rates of specific types of cancer were examined, they were comparable to
the statewide averages also. In those few instances where rates for certain types of
cancer were noticeably higher or lower, the difference is most likely due to the natural,
random variability in cancer occurrence, Bender said.
For the eight communities where PFC contamination has raised health concerns
(Cottage Grove, Hastings, Lake Elmo, Newport, Oakdale, South St. Paul, St. Paul Park
and Woodbury), the distribution of 16 cancer types was similar to the metro -wide
pattern. For the most part, the observed and expected numbers of cancers were
similar. There were some rates that were significantly high, some that were
significantly low, and these varied according to gender and occurred over a number of
communities. No pattern emerged.
"It is often very difficult to look at cancer rates in small populations and discern any
kind of useful or informative pattern or attribute any kind of pattern to low -level
environmental exposures," Bender said. "There are many factors that need to be
accounted for: many types of cancer are generally very prevalent in our society as a
whole, so pockets of excess will naturally appear from time to time and place to place;
risk factors for cancer can include age, gender, race and family history, as well as
lifestyle choices such as smoking, alcohol consumption, diet, exercise and so on."
One of the most telling and problematic factors for looking at cancer rates in the
Washington County area is that a large percentage of the population did not reside
there more than five years ago, yet the latency for most cancers is typically decades
long, Bender noted.
Report on cancer occurrence in Washington, Dakota counties shows rates fall within expected rang... Page 3 of 3
Copies of the report are available on the MDH Web site at www.health.state.mn.us
CAM1
I
N=
t Retur t0 top MDH H ome I News Releases
Updated Wednesday, 06- Jun -2007 14:13:55 CDT
htip: / /www.health.state.mn.us/ news /pressrel /cancerO6O7O7.html 8/4/2010
r
1 • . IMOVIIIIIININ
. s.
FOR B42A MIATE RELEASE August 15, 1994
r -
Contact: Susan Brustman (612) 296 -7769
Toll free or TTY: 1 -800 -657 -3864
TTY: (612) 282 -5332
� ;s ou _ • ► _: u • ■ • ■• �
"Good news for the environment" is Minnesota Pollution Control Agency (MPCA)
Commissioner Charles Williams' description of the outcome of a four -year, mull -media
environmental monitoring study in the vicinity of the 3M Cottage Grove facility. The study
concludes that past emissions from the 3M incinerator at the ration have not affected the
environment and that current emissions do not pose a risk to public health.
The environmental monitoring study was the outcome of a 1989 agreement between 3M
and the MPCA. To conduct the study, 3M contracted with an environmental consultant company,
and the MPCA contracted with three environmental science professors from the University of
Minnesota to serve as an independent review team.
Dr. Robert P. Bringer, vice president in charge of 3M's environmental services said, "3M
has worked closely with the MPCA and the independent review team in the design and
implementation of the study. The good news for 3M and the community in the vicinity of the
facility is that there has been no significant chemical accumulation due to past air emissions from
the facility. Furthermore, current air emissions are not contributing to measureable change in the
same environment."
1
ow
3M ENVIRONMENTAL MONTTORING
August 15, 1994
Page Two
Soil testing near 3M Cottage Grove showed no pattern of accumulation of metals resulting
t ►' 11 tl 1. i:Itl t 1. t. 1• l�`I
adver affec the r epo rt says. Overa incinera emissi con 11 ....
per o the iY. part f ound on the fil was ► i# that inciner e m i ss i on s
contributed some pollutants, but the total concentration of the pollutants was very - when
c ompared to concen that could be P" [ to affect human hea
'IP PI' tt
3M Cottage Grove Facility
Environmental Monitoring Study Summary and Ris Analys s
1.0 EXECUTIVE SUMMARY
A multi -media (air, soil, sediment) environmental monitoring study ( "Study ") has been performed
for the 3M Cottage Grove Facility ( "Facility ") by RUST Environment & Infrastructure, in
cooperation with the Minnesota. Pollution Control Agency, an Independent Review Team (composed
of three University of Minnesota faculty members) and several additional University faculty
members. A total of nine Ph.D. scientists were involved in this project. The focus of the Study was
the corporate incinerator located at the northwest corner of the 3M Facility, although facility
emissions from numerous buildings were initially examined. This document summarizes the
findings of all previous technical reports in this Study and presents a risk analysis of the data
obtained.
The overall Environmental Monitoring Study objectives were defined as follows:
• To assess the Facility's current impacts on human health.
• To determine whether any substances emitted from the Facility in the past have
accumulated in the surrounding environment.
• To provide baseline data from which any accumulation of future emissions from the
Facility can be judged.
• To verify the computer - generated air dispersion modeling previously conducted on the
Facility.
r
The first objective in the Study, assessment of the Facility's current impacts on human health, was
addressed through a chemical screening analysis, followed by ambient air monitoring of chemical
emissions. Based on the screening analysis, only emission substances from the corporate incinerator
and the Facility boiler were selected for the monitoring program. A specific approach, called source -
receptor modeling, was then used to ascertain impacts to ambient air. In this approach, ambient air
sample monitors were strategically placed at varying distances around the 3M Facility. Then,
periodically throughout a one year period, select samples were taken from each monitoring station
and analyzed for 43 chemical constituents. The monitor locations,•the samples selected and the
analyses performed were all chosen based on a project plan approved by the MPCA and the
Independent Review Team.
Simultaneously with this monitoring effort, chemical emission profiles were developed for the
incinerator and for other sources of particulate air emissions in the area. For this Study, these other
non -3M sources included:
- Other regional combustion sources - Regional urban aerosols
- Transportation - Sampling equipment
- RegionaI industries - Wind -blown soil (dust)
The source - receptor model then evaluated the ambient air chemical data at each monitoring station
with respect to these source profiles to ascertain the most likely combination of sources that would
explain the chemistry of each sample.
W/R13M/OVERVI2.SAF
1 -1
December 1994
/.
3M Cottage Grove Facility
Environmental Monitoring Study Summary and Risk Analysis
The results of this analysis revealed that:
(a) the overall air quality in the vicinity of the 3M Facility is generally excellent; that is, both
the particulate concentrations and lead levels measured at each monitoring location were
well below their respective National Ambient Air Quality Standards.
(b) the major contributors to the relatively minor air pollution that does exist in the area are
wind -blown soil, transportation and regional urban aerosols.
(c) the corporate incinerator emissions account on average for less than one percent of the total
particulates measured in the air during this Study.
Maximum possible health risks to the surrounding Cottage Grove Community were then estimated
using surrogate (i.e., hypothetical) individuals located at each of these monitoring locations.
Surrogate resident individuals were assumed to continuously inhale air at four of these locations (P-
1, P -3, P -4 and P -5) 24 hours a day, 365 days a year for 30 years. Since monitor P -2 was located on
3M property, a surrogate worker was assumed present at this location. The results of this "worst
case" analysis revealed health risks well below the level of concern established by the Minnesota
Department of Health. Therefore, it was concluded that the current emissions from the 3M Cottage
Grove incinerator are not likely to present a health threat to the neighboring community.
Regional soil and sediment sampling were initially slated to address Study objectives two and three.
However, due to a lack of suitable sampling locations, sediment sampling was dropped from the
overall Study. One hundred and ninety -eight soil samples were taken during 1992 in the vicinity of
the Facility. These samples were collected from five agricultural locations and six forested land
locations. At each location, nine samples were collected for chemical analysis and nine as back -up
samples. All 99 primary samples were forwarded to an analytical laboratory for extensive chemical
characterization. (Since the confidence interval goals were met for the analytical data using the
primary samples, the back -up samples were not analyzed.)
More than 25 chemical parameters were quantified in the soil samples by the laboratory. To
determine if there were incinerator impacts to soils, a comparison was made between chemical
concentrations at locations where impacts were expected to be the greatest (based on dispersion
modeling and/or proximity to the facility) and chemical concentrations at sites viewed as low impact
areas. Although statistically significant differences in a few metal concentrations were observed
between the two site groupings, only one chemical in the forested samples only (mercury) was
potentially associated with the incinerator. Since there was no consistent concentration pattern
revealed by the statistical analysis, the conclusion from this portion of the Study was that operation
of the 3M Cottage Grove incinerator to date has not led to an accumulation of chemical contaminants
in area soils. The analytical data obtained from this portion of the Study will now serve as baseline
(or starting) conditions from which future impacts by the Facility can be judged.
The ambient air sampling data were also used to determine the accuracy of the computer - generated
air dispersion modeling previously conducted on this facility. Air dispersion modeling is typically
conducted on large emission sources as part of their air permitting by the state and the U.S. EPA.
The 3M Cottage Grove Facility had recently conducted such a model as support documentation for
WIRI3MIOVERV(2.SAF 1 -2 December 1994
3M Cottage Grove Facility
Environmental Monitoring Study Summary and Risk Analysis
their current permit_ Data from this Study were used to verify that the model - predicted air impacts
from the incinerator were conservative.
1°3 noromhor 1906
' c¢u�uyf OR 9
MAJOR POINTS ABOUT THE 3M COTTAGE GROVE
ENVIRONMENTAL MONITORING STUDY (EMS)
1. Study required by the 1989 Stipulation Agreement between 3M and the MPCA
2. A major factor in the success of the study was 3M's cooperative approach
3. A second factor was the use of an Independent Review Team:
• 3 university professors selected by the MPCA and under contract to the MPCA
• helped determine the best approach to the study given the limited dollars available
and the numerous pollutants to consider
• settled technical issues quickly
• helped move the study forward to completion
• provided expertise in numerous technical areas to enhance the study
soils, sediment, aquatic systems, atmospheric deposition, soil -plant interactions,
metals, organic compounds, transport and fate of pollutants, environmental
chemistry, sample collection and laboratory analytical methods, and statistical
analysis.
4. Study did not address all issues at the 3M Cottage Grove Facility. However, a key issue for
3M and the MPCA has been incinerator metal emissions and results from this study include:
• past emissions of metals have not accumulated in the local environment;
current emissions of metals are barely detectable at ambient air monitoring sites and
are not considered to be a health risk.
5. Final reports for the study were approved by the MPCA on August 15, 1994.
6. A Press Release was also issued on August 15 to inform the public of the study's completion.
7. This study will be used by the MPCA as a model for other environmental monitoring studies
that may be conducted in the future.
8. Completion of the EMS fulfills all the requirements in the 1989 Stipulation Agreement