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HomeMy WebLinkAbout2012-03-21 PACKET 00 (6:00 WORKSHOP)* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * COUNCIL ACTION REQUEST Workshop: 3M Incinerator Review —PCA and 3M Representatives will be present. SUPPORTING DOCUMENTS ❑ MEMO /LETTER: ❑ RESOLUTION: ❑ ORDINANCE: ❑ ENGINEERING RECOMMENDATION: ❑ LEGAL RECOMMENDATION: ® OTHER: Memo from SEH 2009 ETF Report Public Hearing Notice Draft Air Emission Report Technical Support Document Draft RCRA Permit Reissue 3M's RCRA Permit Renewal Application Memo of Understanding CG and 3M ADMINISTRATORS COMMENTS Administrator Date ***************** * * * * * * * * * * * * * * * * * * * * * * * * * * * * * ** COUNCIL ACTION TAKEN: ❑ APPROVED ❑ DENIED ❑ OTHER Document2 /J SEH MEMORANDUM TO: Jennifer Levitt, PE, City of Cottage Grove FROM: Thomas Henning, PE, SEH DATE: March 8, 2012 RE: Comparison of Draft Changes to the 3M Incinerator Air and Hazardous Waste Permits SEH No. 119210 -02 In response to your request, Short Elliott Hendrickson, Inc. ( "SEH ") has conducted a review of draft permits for the 3M Corporate Incinerator operated at the 3M Cottage Grove facility. The two permits for the 3M Corporate Incinerator, the Title V Air Emission ( "Air ") Permit and the Hazardous Waste Storage and Treatment Facility ( "Hazardous Waste ") Permit, are being renewed and updated by the Minnesota Pollution Control Agency ( "MPCA "). The draft permits have been made available to the public for comment. After addressing comments received on the draft permits, the MPCA is expected to issue the final permits during late spring or early summer 2012. The Air Permit focuses on air emissions from the incinerator, whereas the Hazardous Waste Permit focuses on waste handling and storage activities. This memo presents the main changes in the draft permits compared to current versions and the environmental and emission impacts of these changes. Many permit conditions, such as incinerator feed rate limitations and operational practices, are found in both the Air and Hazardous Waste Permits. Therefore, because of this overlap, this memo will present changes in the two permits together. For the remainder of this memo, the 3M incinerator's new Air and Hazardous Waste Permits will be referred to as "the Permits ". One significant change in the Permits allows 3M to receive and process hazardous waste that was not produced at a 3M facility (referred to as "non -3M Waste "). Previously 3M only processed waste that was generated at a 3M plant. Because the amount of solvent waste generated by 3M has decreased in past years, 3M currently uses natural gas to supplement 3M waste in order to maintain the required operation temperatures in the incinerator. Because other wastes could be used for this purpose instead of natural gas, 3M hopes to utilize solvent waste from non -3M sources to replace natural gas in the incinerator. Memorandum of Understanding Between 3M and the City of Cottage Grove The City of Cottage Grove entered into an agreement with the 3M to request MPCA to include limits in the Permits regarding the processing of non -3M Waste. The conditions of the agreement are documented in a Memorandum of Understanding between the two parties dated August 11, 2010 ( "2010 MOU "). Each of the requested issues presented in the 2010 MOU have been incorporated into the Permits. Limitations on Wastes In the Permits, the 3M is authorized to process: 1. Any hazardous wastes generated by 3M operations, or 3M wastes from vendor facilities, within North America ( "3M wastes "). Short Elliott Hendrickson Inc., 3535 Vadnais Center Drive, St. Paul, MN 55110 -5196 SEH is an equal opportunity employer I www.sehine.com 1 651.490.2000 1 800.325.2055 1 651.490.2150 fax Comparison of Draft Changes to the 3M Incinerator Air and Hazardous Waste Permits March 8, 2012 Page 2 Bulk hazardous wastes from non -3M sources ( "non -3M wastes "), limited to 400,000 MMBtu per year. Non -3M wastes must: a. originate within the United States b. be a solvent or exhibit ignitability (i.e. must have one of five eligible waste codes) c. be provided without any payment or compensation to 3M An unlimited amount of controlled substance wastes seized or collected by Minnesota law enforcement agencies ( "law enforcement wastes "). Law enforcement wastes are not included in the yearly limit for non -3M wastes. The waste limitation language listed in the Permits is nearly identical to the waste limitation language in the 2010 MOU. There are no federal or state regulations that would require 3M to limit non -3M waste processing, so the 2010 MOU clearly is the basis for non -3M waste limitations in the Permits. Because natural gas would be replaced by non -3M wastes in the incinerator under the above permit conditions, changes in pollutant emissions could result. The MPCA estimates increased emissions from the replacement of natural gas with non -3M solvent waste under `worst case' assumptions. Worst case emission increases are less than 1.1 tons per year (or 11 %) for PM and less than 0.1 ton per year (or <1 %) for VOCs. Potential emission changes for other pollutants were not provided by the MPCA. ,Updated Risk Assessment As a hazardous waste combustor, the 3M incinerator is required to conduct (and updated as needed) a Human Health Risk Assessment (HHRA). The most recent incinerator HHRA was conducted in 2004. In the Permits, the MPCA requires 3M to update the incinerator's HHRA. The update will incorporate new technical guidance provided by the United States Environmental Protection Agency and will include new methodologies to evaluate the impact from mercury emissions. 3M's HHRA work plan must be submitted to the MPCA for approval within 90 days of issuance of the Permits. If the updated HHRA shows a potentially unacceptable human health risk, then the Permits will be modified to reduce relevant emissions. This HHRA update was specifically requested in the 2010 MOU. Incinerator Inspections Occasional compliance inspections of the 3M incinerator by the MPCA are authorized by the Permits. The 2010 MOU requested that MPCA conduct these inspection on a more random and unannounced basis. Because the nature of MPCA inspections is not addressed in the Permits, it is not expected that this request would be addressed by permit language. Other Changes in Draft Permits In addition to the permit changes requested in the 2010 MOU, other changes in the draft Permits are presented below. Revised Waste Analysis Plan 3M is required by the Permits to follow waste handling and testing procedures described in the Waste Analysis Plan (WAP) so that wastes are properly sampled, tested, and verified. The WAP has been updated to add requirements to monitor incoming non -3M wastes. The updated WAP also requires additional testing of non - production 3M generated wastes and low- volume waste streams. The additional testing measures require 3M to gather more information on the wastes received and processed in the incinerator. These updates ensure that proper procedures are in place to manage 3M and non -3M wastes. Comparison of Draft Changes to the 3M Incinerator Air and Hazardous Waste Permits March 8, 2012 Page 3 Lower Allowable Emissions Allowable emission rates for several pollutants have been lowered in the Permits. These emission limit changes (shown in Table 1) are the result of data from the most recent incinerator performance test (required every 5 years) and revisions to federal emission standards for incinerators. It should be noted that new emission limit for mercury, 0.004 pound per hour, is lower than the Minnesota state limit of 0.006 pound per hour. This lower 3M emission limit was voluntarily accepted by 3M. Table 1. Current and New Permitted Incinerator Emission Limits *New emission limit voluntarily accepted by 3M. ppmv = parts per million by volume µg/dscm = micrograms per dry standard cubic meter More Restrictive Operational Limits The limits for several operating parameters have also been revised in the Permits. These changes (shown in Table 2) are the result of data from the most recent incinerator performance test (required every 5 years). All of these changes would have beneficial emission impacts: decreased hazardous waste throughput and pumpable waste throughput will lower emissions of pollutants and increased kiln temperature will result in greater destruction of combustible pollutants such as carbon monoxide and volatile organic compounds. Table 2. Current and New Permitted Incinerator Operating Parameters Operating Parameter Emission Limit in Emission Limit in Pollutant Current Permit Draft Permit Lead + Cadmium 240 dscm 230 dscm Arsenic + Beryllium + Chromium 97 dscm 92 dscm 0.006 lb/hr 0.004 lb/hr Mercury* 50.0 dscm 33.0 dscm Hydrochloric Acid and Chlorine Gas 77 ppmv 32 ppmv Total Particulate Matter 34 mg/dscm 29.8 mg/dscm *New emission limit voluntarily accepted by 3M. ppmv = parts per million by volume µg/dscm = micrograms per dry standard cubic meter More Restrictive Operational Limits The limits for several operating parameters have also been revised in the Permits. These changes (shown in Table 2) are the result of data from the most recent incinerator performance test (required every 5 years). All of these changes would have beneficial emission impacts: decreased hazardous waste throughput and pumpable waste throughput will lower emissions of pollutants and increased kiln temperature will result in greater destruction of combustible pollutants such as carbon monoxide and volatile organic compounds. Table 2. Current and New Permitted Incinerator Operating Parameters Operating Parameter Current Operating Limit New Operating Limit Hazardous Waste throughput 23,300 lb/hr 21,800 lb /hr Pum able Waste throughput 17,000 lb/hr 14,800 lb /hr Minimum Temperature in Kiln 1 1,620 °F 1,760 °F Summary The proposed draft Air and Hazardous Waste Permits for the 3M Corporate Incinerator include several changes compared to the current permits. These changes, some of them voluntarily accepted by 3M, include limitations on non -3M waste processing, an update of the Human Health Risk Assessment, and revised emission and operating limits. All of the applicable changes proposed in the 2010 MOU between 3M and Cottage Grove are represented in these changes. Overall, these Permit changes will not result in significant emission increases of pollutants. SDP /sdp /TAH pAae \c \cottg \119210\memo - 3m permit changes_03- 07- 12.doc • • •;I • , • . • • 1 •:. 1 l I 1, 0 FM M • Since 1971, 3M has operated a corporate hazardous waste incinerator at its Cottage Grove plant. Under Minnesota Pollution Control Agency (MPCA) permits, only waste products generated by 3M may be processed at the incinerator. In March 2009, 3M requested a modification from the state air emissions and hazardous waste permits to allow 3M to accept and process non -3M generated hazardous wastes. The purpose for this request is to allow 3M to accept wastes with high fuel value to replace the natural gas and fuel oil currently used to fuel the incinerator. In addition, as part of the modification to the permits, the MPCA requested that 3M also process at the incinerator wastes generated by Minnesota law enforcement agencies. • This report includes the following elements: • A description of the incinerator • A description of the MPCA permitting process • Analysis of emissions monitoring data ® Recommendations on the City's response to the 3M permit modification request. Cottage Grove Environmental Task Force To allow time for the City of Cottage Grove to study the incinerator request, in May 2009, 3M voluntarily suspended its requested permit modification. The City subsequently formed an Environmental Task Force to review issues related to the incinerator and provide a recommendation to the City Council. The City also contracted with SEH, Inc. to provide technical assistance to the Task Force and City staff. The Task Force has met six times on the proposal: August 5, 2009 — The Task Force participated in a tour of the facility. August 19, 2009 — Presentations by the Minnesota Pollution Control Agency and 3M on the incinerator proposal. September 9, 2009 — Discussion of issues involving the incinerator proposal. September 23, 2009 — The Task Force held a public forum on the proposal attended by approximately 30 Cottage Grove residents. Thirteen residents spoke on the issue. October 14, 2009 — Discussion of issues raised at the public forum. October 27, 2009 — Review of final report on the incinerator. The minutes of the Task Force meetings on the incinerator are attached. H 2. Incinerator Background As noted above, 3M has operated an incinerator at the 3M Cottage Grove facility since 1971. The original incinerator was replaced and upgraded in a series of improvements from 1996 to 2005. The primary fuel for the incinerator is solvent waste. These solvents are supplemented by natural gas and fuel oil to maintain operating temperatures of 1,800 ° F to 2,000 ° F in the incinerator. The following description of the incinerator is included in the technical support document prepared by the Minnesota Pollution Control Agency for the air emissions permit for the incinerator: The 3M Company (Permittee) Cottage Grove Center (Facility) is located at 10746 Innovation Road, Cottage Grove, Minnesota. 3M operates a thermal treatment system under separate air quality and hazardous waste permits. The 3M Corporate Incinerator consists of a rotary kiln and a secondary combustion chamber (SCC) followed by a wet off -gas cleaning system. The off -gas cleaning system consists of a quench chamber, a subcooler, a particulate removal device known as the M1 module, a wet electrostatic precipitator (WESP), an induced draft fan, and an exhaust stack. Also located at this Facility are indoor and outdoor container storage areas, outdoor tank storage areas, a containment building for bulk solids storage, a tanker truck unloading area, outdoor trailer storage, indoor and outdoor material handling areas, and a rotary kiln incinerator with a secondary combustion chamber. These units provide treatment and storage of hazardous waste generated by 3M's operating divisions. No disposal of hazardous waste is conducted at this Facility. The material storage and -2- handling areas of the facility are permitted under a separate RCRA permit and are not covered under this air emissions permit. This permit authorizes the operation of the combustion system consisting of a rotary kiln and a secondary combustion chamber. The rotary kiln is 40 feet long, has a shell diameter of 14 feet 9 inches, and is designed as a primary combustion chamber. The secondary combustion chamber is 60 feet high and has a shell diameter of 20 feet. It provides additional residence time to combust off -gases of organic wastes. An emergency vent stack is provided at the roof of the secondary combustion chamber. The combustion system has no boiler. This permit does not authorize the installation of a future boiler. The 3M Corporate Incinerator, which includes container and tanker storage areas, provides treatment and storage for business - related wastes generated by 3M's operating divisions throughout North America. The Incineration system is designed to handle a variety of wastes introduced through four separate feed systems. Materials can be fed to the rotary kiln by four means depending on the waste stream. Solids are fed through a bulk feed chute (pakfeeder and Komar shredder); pumpable liquids are fed through lances or the frontwall burner; sludge is fed through a lance from either the Building 145 sludge room or the Building 47 pump room; and direct burn wastes are fed through a lance. Pollution control is facilitated with several flue gas treatment devices. The incinerator exhaust gases are saturated and cooled in the quench chamber. Flue gases then pass through a subcooling tower and filtering module. Final pollution control is provided by a wet electrostatic precipitator. Flue gases are pulled through the system with an induced draft fan and exhausted through a 165 -foot stack to the atmosphere. -3- Hazardous waste is shipped to the Facility via semi - trailers in 55- gallon steel drums, totes, plastic and fiber drums, pails, boxes, bags, portable tanks, and tanker trucks. The types of containerized wastes received include solids, gases in cylinders, pumpable sludges, organic liquids, and aqueous liquids. (Source: MPCA Technical Support Document for Air Emission Permit No. 16300025 -001) 3. Air Permitting Issues 3M Incinerator Air Permit The incinerator operated at 3M Cottage Grove is subject to several state and federal air quality regulations and permitting requirements. The Minnesota Pollution Control Agency (MPCA) has issued an air operation permit for the incinerator, Permit Number 16300025 -001. In addition to containing emission limits applicable to the incinerator, the air permit also documents required recordkeeping, monitoring, testing, and reporting requirements. There are several pollution control devices operated in conjunction with the incinerator which are designed to control emissions. Each of the pollution control devices have operation conditions that must be continually met in order to demonstrate the devices are functioning properly. For example, the electrostatic precipitator (a device designed to control particulate matter (dust) from the incinerator) must maintain a sufficient electric current to work properly. Also, the incinerator kiln must be maintained at a minimum temperature to ensure organic material is completely burned. The incinerator is subject to several state and federal air quality regulations. One of the most important regulations is call the National Emissions Standards for Hazardous Air Pollutants. This federal rule established emission rates and other requirements to ensure proper control emissions of hazardous air pollutants such as lead, cadmium, arsenic, beryllium, chromium and mercury. Regarding mercury, 3M has accepted a permit limit for mercury that is less than half of the federal mercury emission standard. The lower emission limit was accepted at the request of MPCA because of Minnesota's focus on reducing state wide mercury emissions. The rule also establishes required performance levels for pollution control equipment. The facility is also required to meet state and federal ambient air quality standards. Emissions from the incinerator must not cause air quality outside of 3M's property to degrade below these standards. The permit contains emission limits and recordkeeping requirements to ensure these standards are met. Air Permit Renewal Process The 3M Incinerator air permit was issued on February 14, 2005. The permit is valid for five years, that is, it expires on February 14, 2010. 3M is required to submit a permit renewal application at least 180 days prior to the expiration date. Therefore the renewal application was due by August 18, 2009. 3M submitted a renewal application prior to this date. The MPCA will review the application and prepare a draft permit. The new draft permit will reflect any changes proposed by 3M in their renewal application and will incorporate any new -4- applicable air quality regulations that may have come into effect since the initial permit was issued. The MPCA will also prepare a "Technical Support Document' in which MPCA will document the technical review they conducted while preparing the draft permit. The Technical Support Document also provides the legal and factual justification for each applicable requirement or policy decision considered in the issuance of the draft permit. When complete, the draft permit and Technical Support Document will be made available to the public for review and comment. The comment period lasts for 30 days. Written comments on draft permit must be considered by MPCA. Members of the public or organizations can request that a public information meeting be held. MPCA generally grants these requests as long as the reason for the request is a legitimate concern related to the air permit. In addition to the 30 -day public comment period, the United States Environmental Protection Agency (EPA) is also given a 45 -day comment period. EPA's comment period typically runs concurrent with the public's 30 -day comment period. MPCA only issues the permit after all comments related to the air permit are addressed. Note that MPCA will typically not respond to comments on issues unrelated to the air permit such as land use, zoning, traffic, or environmental impacts unrelated to air emissions. Inspections and Required Reports MPCA staff conducts inspections of regulated facilities every two years. Although MPCA has the authority to conduct unannounced inspections, their policy is to provide the facility at least a couple days' notice of an upcoming inspection. SEH reviewed the inspection reports for three facilities operated at the 3M Cottage Grove plant (see Section 3.2.3). The 3M Incinerator permit contains reporting requirements. For example, 3M is required to submit an annual compliance certification for the incinerator. Deviation reports are required semi annually (every six months). SEH reviewed the compliance certifications and deviation reports for three facilities located at the 3M Cottage Grove plant (see Section 3.2.4). 4. Review of Monitoring Data SEH conducted a review MPCA files for the 3M Cottage Grove facility. SEH focused the review on three facilities at the 3M Cottage Grove Complex: the incinerator (since it is the focus of the Task Forces' efforts), the Tape Manufacturing plant and the Materials Resource Division. The latter two are included since most of the emissions from 3M Cottage Grove originate from these operations. In addition, we requested information from the MPCA for years 2006, 2007, and 2008. Below is a summary of the information received. Review of Emission Test Results A January 14, 2008 letter from MPCA to 3M Cottage Grove documented the results of emission testing conducted on emissions from the incinerator. Testing was performed on four dates, August 20, 2002; November 5, 2002; May 8, 2003; and August 17, 2004. The summary documents that all of the testing demonstrated compliance with permit emission limits. The results of each test and the allowable emission limits are shown on Table 1. -5- Table 1. Stack Test Results 3M Cottage Grove Incinerator Note: ug /dscm = micrograms per dry standard cubic meter lb/hr = pounds per hour gr /dscf = grains per dry standard cubic foot An October 13, 2006, letter from MPCA to 3M Cottage Grove documented the results of emission testing conducted on the two thermal oxidizers operated at the Tape Manufacturing plant at the 3M Complex. The thermal oxidizers are used to destroy solvents and other volatile compounds use on two tape "makers." The two oxidizers are required to achieve at least 95 percent destruction efficiency of volatile organic compounds (e.g. solvents). The "Maker 11" thermal oxidizer achieved 98.1 and 96.3 percent destruction efficiency (3M used two different tests to verify compliance). The "Maker 14" thermal oxidizer achieved 99.6 and 97.4 percent destruction. The tests show that both thermal oxidizers achieve their required destruction efficiency. Review of Compliance Inspections The file review included the results of several Air Quality Compliance Inspections conducted by MPCA staff for the three facilities. SEH reviewed inspection results conducted during 2005, 2007, and 2009 for the Materials Resource Division; 2005, 2007, and 2009 for the Tape Manufacturing Plant; and 2006 and 2008 for the incinerator. The results of each compliance inspection concluded that "No emissions violations of applicable Minnesota air quality rules were observed at the facility." However, some of the inspections generated some dialogue between 3M and MPCA staff regarding the specifics of some recordkeeping and reporting requirements. On Table 2 we show the dates and facilities covered by each inspection and a description of issues discussed during the inspections. -6- Results of Emission Permit Tests 8/20/2002 11/512002 5/8/2003 8/1712004 Pollutant Limits Units Arsenic + Beryllium + 97 ug /dscm 3.9 12.4 Chromium gram /24- Beryllium 10 hour < 0.56 < 0.55 < 0.48 Cadmium + Lead 240 u /dscm 185.1 47.8 Hydrogen Chloride 4.0 lb/hr < 0.052 0.34 0.07 Mercury 50 u /dscm 2.6 1.9 0.25 Opacity 20 Percent 2.5 1.5 Particulate Matter 0.06 r /dscf 1 0.010 0.0048 0.010 1 0.026 Note: ug /dscm = micrograms per dry standard cubic meter lb/hr = pounds per hour gr /dscf = grains per dry standard cubic foot An October 13, 2006, letter from MPCA to 3M Cottage Grove documented the results of emission testing conducted on the two thermal oxidizers operated at the Tape Manufacturing plant at the 3M Complex. The thermal oxidizers are used to destroy solvents and other volatile compounds use on two tape "makers." The two oxidizers are required to achieve at least 95 percent destruction efficiency of volatile organic compounds (e.g. solvents). The "Maker 11" thermal oxidizer achieved 98.1 and 96.3 percent destruction efficiency (3M used two different tests to verify compliance). The "Maker 14" thermal oxidizer achieved 99.6 and 97.4 percent destruction. The tests show that both thermal oxidizers achieve their required destruction efficiency. Review of Compliance Inspections The file review included the results of several Air Quality Compliance Inspections conducted by MPCA staff for the three facilities. SEH reviewed inspection results conducted during 2005, 2007, and 2009 for the Materials Resource Division; 2005, 2007, and 2009 for the Tape Manufacturing Plant; and 2006 and 2008 for the incinerator. The results of each compliance inspection concluded that "No emissions violations of applicable Minnesota air quality rules were observed at the facility." However, some of the inspections generated some dialogue between 3M and MPCA staff regarding the specifics of some recordkeeping and reporting requirements. On Table 2 we show the dates and facilities covered by each inspection and a description of issues discussed during the inspections. -6- Table 2. Summary of Compliance Inspections Facility Date of Follow -up Discussion Points Inspection Materials Resource January 25, 2005 MPCA requested that 3M: Division • Calculate rolling 12 month emission totals upon issuance of the 16300022 permit. • Document that PM10 emissions emitted is equal to PM emissions. • Include building number, unit descriptions, and permit ID numbers on the required equipment list. September 6, 2007 No follow-up items June 26, 2009 Records search did not include letter with follow -up items. Tape Manufacturing March 30, 2005 • Even though the permit only requires weekly throughput 16300080 calculations, MPCA states that 3M must also demonstrate compliance with a monthly throughput limit. • MPCA requested that 3M clarify how actual monthly VOC usage will be calculated • MPCA clarified reporting requirements related to the two thermal oxidizers operated at the plant. Sept mber 7, 2007 No follow-up items June 25, 2009 Records search did not include letter with follow -up items. Incinerator June 7, 2006 MPCA requested that 3M: 16300025 • Include Test Methods and Procedures in 3M Leak Detection and Repair SOP. • Organize the equipment shown on their required equipment list into categories. • Update information on mechanical pumps operated at the plant. • Update a Title V notification confirming the applicability of federal control requirements at the plant • Specifically state in deviation reports that no deviations are noted. June 17, 2008 1 No follow-up items Compliance Certifications. Monitorina Resorts and Deviation Resorts Each of the 3M facilities at the Cottage Grove complex are required to submit semi - annual monitoring reports, annual compliance certifications and deviation reports. SEH reviewed reports from 2006 — 2009 for the Material Resource Division, 2005 — 2009 for the Tape Manufacturing Plant, and 2007 — 2009 for the incinerator. In general, few deviations are reported at the Materials Resource Division and Tape Manufacturing Plant. Deviations were commonly failure to verify operation of temperature recording devices. The Incinerator reports had more frequent deviations reported. Examples of deviations reported include out of range carbon monoxide concentrations or kiln temperatures. The reported deviations were typically for very brief durations. A summary of the reports provided by MPCA from the file search is shown on Table 3. -7- Table 3. Summary of Monitorina. Comaliance and Deviation Reports Facility Date of Re ort Deviation Discussions Materials Resource January 27, 2006 No Deviations July 21, 2006 No Deviations Division January 26, 2007 A required report for the Subpart PPP MACT is being submitted 16300022 separatel July 20, 2007 No Deviations January 25, 2008 No Deviations July 27, 2008 No Deviations January 27, 2009 The pH of the Halogen Scrubber operated with the Wastewater Treatment plant dropped below 7.0. The cause was identified and corrected. Documentation of MPCA notification associated with the low pH. Tape Manufacturing July 20, 2005 No Deviations January 12, 2006 On four days between July 16 and December 4, operators failed 16300080 to verify the operation of temperature recording devices on the thermal oxidizers. July 26, 2006 On five days between January 2 and June 25, operators failed to verify the operation of temperature recording devices on the thermal oxidizers. January 5, 2007 No Deviations July 20, 2007 No Deviations January 14, 2008 No Deviations July 22, 2008 No Deviations January 27, 2009 On November 15, operators failed to verify the operation of temperature recording devices on the thermal oxidizers. Incinerator January 27, 2007 . Listed several dates when CO concentrations exceeded 16300025 threshold • Documented events when feed chute relief damper opened • Two incidents when kiln temperature dropped • Documented when subcooler water pressure dropped • Descriptions of monitor downtimes for calibration and maintenance July 26, 2007 . Listed several dates when CO concentrations exceeded threshold • Documented calibration data and startup /shutdown information January 28, 2008 . Site -wide power outage caused a system shutdown. Some operational data was lost during power outage. • Lightning strike caused a shutdown of the system. A burnout of the system was initiated as the severe weather approached. • A bearing failure in the ID fan caused an emergency shutdown of the system. • Documented calibration data and startup /shutdown information July 27, 2009 . Listed several dates when CO concentrations exceeded threshold January 27, 2009 . Listed several dates when CO concentrations exceeded threshold • Power outage caused hazardous waste feed cutoff. Event caused drop in pressure across M1 scrubber. • Excess slag dropping into quench caused E -stack opening • Komar Pressure Relief Panels opened • Excess slag dropped in quench causing a drop in kiln temp. -8- Review Incinerator Operational Data for Day /Night Conditions During the September 23, 2009 Environmental Task Force meeting, members of the public expressed concern that the 3M Incinerator was operated differently at night than during the day. In response to these comments, SEH conducted a review of 3M Incinerator operational data. On September 30, 2009, Kathryn Sarnecki, PE, with SEH visited the 3M Cottage Grove Incinerator. The purpose of the visit was to view operational data from the incinerator. Specifically, SEH was looking for evidence that the incinerator or the pollution control equipment associated with the incinerator is operated differently at night than during the day. Initially, Ms. Sarnecki viewed data generated at the incinerator for the previous 24 hours (from 9:00 a.m. September 29 through 9:00 a.m. September 30). From the incinerator control room she viewed instantaneous results and process averages compared to permit values. Specific parameters viewed were: 1) Kiln exit temperature, 2) Total hazardous mass and total pumpable mass input rates, 3) M1 venturi scrubber pressure differential, 4) Wet electrostatic precipitator power, 5) Ash generation rate, and 6) Material loading rates (e.g. chlorine, arsenic + beryllium + chromium, and lead + cadmium). These parameters are indicative of the loading rates of total waste and specific compounds (such as metals) to the incinerator and the kiln's operating temperature. In addition, this data documents the operation of the primary pollution control equipment (e.g. the venturi scrubber and the electrostatic precipitator). After viewing data for the previous 24 hours, Ms. Sarnecki asked to view data from several other dates selected at random. Care was taken to ensure some of these dates included weekends. Data from the following dates were viewed: • September 27 and 28, 2009 • August 6 and 7, 2009 • June 2 through 9, 2009 • February 18 through 23, 2009 • May 3 through June 6, 2006 Figure 1 shows kiln operating temperatures for sixteen 24 -hour periods between February 22, 2009, and September 29, 2009. The temperatures show no daily fluctuation. The data show the operating temperature dropping from about 2,000 ° F to 1500 ° F during the morning of June 2, then increasing back up to 2,000 ° F during the morning of June 3. Figure 2 shows waste loading rates to the kiln for sixteen 24 -hour periods. No daily fluctuations are apparent from day and night operation. Note that waste loading to the kiln drops to zero during the time period that the kiln temperature lowered to 1,500 ° F. -s- Figure I. Kiln Exit Temperature 2,500 2,000 t 1,500 L IA00 500 — 9129109 — 9/27/09 — 8/7/09 —6/2/09 — 6/3109 — 6/4/09 — 6/5/09 6/6/09 — 6/7/09 ...-6/8/09 — 2/18/09 2/19/09 2/20/09 2/21/09 .2/22/09 Based on this review, SEH saw no significant difference in incinerator or pollution control equipment operation. Although the data varied throughout any given 24 -hour period, the differences between daytime and nighttime operation were negligible. Additionally, no violations of permit requirements were noticed for the parameters examined. Figure 2. Hazardous Waste Loading Rates Si N S L R f — 9129/09 — 9127/09 —W /09 — 6/7/09 — 6/3/09 — 6/4/09 — 6/5/09 — 616109 — 6/7/09 -- 618/09 2/19/09 2/20109 2/21/09 ^° 3M Cottage Grove Emissions 3M Cottage Grove actually consists of several separately permitted operations, one of which is the 3M Corporate Incinerator. Each of these operations has a separate air permit. Table 4 below lists the operations and the Facility Identification number assigned to each operation by the MPCA. -10- 0 08 tiP 14, a e s9 y xP e d' �z9 $ 8 9 d' 08 ti� 6 xP s a° y cP 6 8 9 �c3' n 8 �d' ti xP �cP Time o r9 � 1 39 ,xP a8 y� b� , b d� q 79 a x4 ti eP �' eD psP y'� b� ,�xF c9 97� e� �d' � Thm Table 4. 3M Operations at 3M Cottaae Grove Operation Name Facility ID 3M Cottage Grove - Abrasive Systems Division 16300017 3M Cottage Grove - Building 17 16300023 3M Cottage Grove - Building 133 - Formally TCM 16300059 3M Cottage Grove - Center Utilities 16300015 3M Cottage Grove - Corporate Incinerator 16300025 3M Cottage Grove - Film & Materials Resource Div. 16300022 3M Cottage Grove - Specialty Additives 16300002 3M Cottage Grove - Tape Manufacturing 16300080 Permitted facilities in Minnesota are required to annually report their actual "criteria pollutant" emissions to the MPCA. Every three years (i.e. 2008, 2005, etc.) permitted facilities are required to report annual emissions of additional compounds. MPCA makes this data available to the public on their website at: www.pca.state.mn.us/ air /criteria - emissionsearch.cfm At the request of the Task Force, SEH totaled the annual emissions from each of the 3M operations at the 3M Complex for the three most recent years, 2005, 2006 and 2007 using the data available from the MPCA website. Note that 2008 emission data is not yet available on the website. Table 5 shows emission data from each of the 3M Cottage Grove facilities for the years, 2005, 2006 and 2007. The data show the emissions from the incinerator have been relatively similar for each of these years. For example, volatile organic compound (VOC) emissions have been 20 tons per year (tpy), 30 tpy, and 26 tpy over this period. The data also show that VOC emissions have been consistently higher at the Tape Manufacturing Plant and Materials Resource Division than at the incinerator. Every three years (i.e. 2008, 2005, etc.) permitted facilities are required to report annual emissions of additional compounds. 2008 data is not yet available so 2005 data for additional compounds is shown on Table 6 for each of the 3M Cottage Grove operations. Emissions from the Cogentrix plant which is located next to the 3M plant are also shown. Again, the data show that emissions from the Tape Manufacturing plant and Materials Resource Division are generally higher than from the other operations including the incinerator. SEH also evaluated heavy metal emissions from the incinerator. For this evaluation, SEH prepared a comparison of the allowable heavy metal emission rates with actual emission rates. The 3M Cottage Grove incinerator air permit limits the concentration of several heavy metals in the exhaust from the incinerator. The permit also limits the amount of exhaust gas from the incinerator to less than 40,000 dry standard cubic feet permit minute (dscfm). Using the concentration limits and the exhaust flow limits SEH calculated allowable emission rates based on continuous operation of the incinerator. Please note the following: 1) Many of these metals are limited as groups of compounds. For example, the total amount of arsenic, beryllium and chromium cannot exceed a concentration of 97 micrograms per dry standard cubic meter (ug /dscm). 2) The federal limit for mercury is 130 ug /dscm. However, 3M is limited to a more restrictive concentration of 50 ug /dscm based on an agreement with MPCA. M Table 7 shows the comparison of allowable emission rate to actual emission for several heavy metals. Actual emissions of each compound or group of compounds are less than their respective allowable emission levels. Table 7. Allowable vs Actual Emission Rates 3M Cottage Grove Incinerator Incinerator Exhaust Flow Limit': 40,000 dscfm Pollutant 2005 Actual Emissions lb/ r Permit Limits' u /dscm Allowable Emission Rate, lb/ r Actual/ Allowable Percent Arsenic Beryllium Chromium 0.0000024 0.0000018 2.0 Total 2.0 97 127 1.6% Beryllium alone 0.0000018 10 /24 -hr 8.0 0.000023% Cadmium Lead 6.65 3 56.39 Total 63.04 240 315 22% Mercury 0.0000018 50 66 0.000003% Mercury NESHAP Limit 130 171 0.000001% Notes: ' Exhaust flow and emission limits are taken Pages A -25, A -26 and A27 of the 3M Cottage Grove air permit (16300025 -001). 2 2005 Actual Emissions taken from MPCA's website, www.pca.state.mn.us/ air /criteria - emissionsearch.cfm 3 Levels of cadmium and lead corrected from early version of table. 5. Recommendations Through discussions with 3M, they have committed to providing an annual report to the City for the incinerator that will address the following topics: a) Total emissions levels. b) Compliance with MPCA operational parameters. c) Plans to reduce peak emissions levels of carbon monoxide. d) Compliance with 3M Environmental Targets. e) Procedures to minimize the effects of severe weather and incinerator. power outages at the am 3M has also committed to working with the Cottage Grove Environmental Task Force to study air and water emissions from sources other than the incinerator at the 3M facility and explore means of reducing emissions levels. On October 27, 2009, the Environmental Task Force reviewed the final report and provided the following recommendations to be presented to the MPCA in its consideration of the 3M request for a permit modification: 1) Commercial Incineration That 3M voluntarily include a condition in any MPCA permit modification and 2010 renewal for the incinerator which prohibits commercial incineration at the facility. Commercial incineration is defined as 3M accepting payment or other compensation for burning wastes generated by non -31VI sources. 2) Non -3M Wastes Allowed That 3M voluntarily include a condition in any MPCA permit modification and 2010 renewal to accept only bulk wastes with high BTU content from non -3M sources. All non -3M generated wastes must have one of the following waste codes listed in the hazardous waste manifest: F001, F002, F003, F005, D001, and codes related to law enforcement wastes. 3) Limits on Non -3M Wastes That 3M voluntarily include a condition in any MPCA permit modification and 2010 renewal to establish a maximum limit of non -31VI wastes of 400,000 million BTU per year of wastes burned at the incinerator from sources within the United States. 4) Law Enforcement Materials Only materials from Minnesota law enforcement agencies will be accepted by 3M for processing at the incinerator. 5) Risk Assessment With the 2010 permit renewal, an update shall be prepared of the 2004 Human Health and Ecological Risk Assessment for the incinerator. 6) Incinerator Inspections. The City requests that inspections of the 3M Corporate Incinerator which are conducted on a two -year basis be conducted in a more random and unannounced nature. -13- MINNESOTA POLLUTION CONTROL AGENCY PUBLIC NOTICE AND NOTICE OF PUBLIC MEETING R k NOTICE IS HEREBY GIVEN, that the Commissioner of the Minnesota Pollution Control Agency (MPCA) proposes to issue Air Emission Permit No. 16300025 -002, and Hazardous Waste Facility Permit No. MND006172969, to 3M Company for their facility located at 10746 Innovation Road, Cottage Grove, Washington County, Minnesota. Additionally, in anticipation of a request for a public meeting, the MPCA will host a public informational meeting to discuss the draft Hazardous Waste Facility and Air permits for the facility. This meeting will be on Tuesday, April 10, 2012, at Cottage Grove Middle School Cafetorium, at 6:30 p.m., located at 9775 Indian Boulevard South in Cottage Grove. The permit action is for reissuance of the Hazardous Waste Facility permit; and a major amendment and reissuance of the Part 70 Air Permit; therefore the draft permits have been placed on public notice. The permits allow 3M to operate a hazardous waste incinerator on the property. The reissuance of the permits would also allow 3M to accept non -3M source material with fuel value to supplement and reduce the amount of fossil fuels required to maintain operating temperatures in the incinerator; and allow 3M to accept Minnesota Law Enforcement Agency controlled- substance wastes as a public service. The State of Minnesota is authorized to administer its hazardous waste program (in lieu of the federal hazardous waste management program). A summary of the Total Facility Limited Potential to Emit (PTE) in tons per year of air emissions is as follows: PM = Particulate Matter NO, _ Nitrogen Oxides PM PM smaller than 10 microns S0 = Sulfur Dioxide PM = PM smaller than 2.5 microns VOCs = Volatile Organic Compounds CO = Carbon Monoxide HAP = Hazardous Air Pollutant The Permittee has submitted a pollution prevention progress report pursuant to Minn. Stat. § 115D.08. The preliminary determination to issue the permits is tentative. There are four formal procedures for public participation in the MPCA's consideration of the permit application. Interested persons may (1) submit written comments on the draft /proposed permit; (2) request that the MPCA hold a public information meeting; (3) request the MPCA hold a contested case hearing; and /or (4) submit a petition'to the Commissioner requesting that the MPCA Citizens' Board (Board) consider the permit matter. The decision whether to issue the permits and, if so, under what terms, will be presented to the Board for decision if: (1) the Commissioner grants the petition requesting the matter be presented to the Board; (2) an Board member requests to hear the matter prior to the time the Commissioner makes a final decision on the permit; or (3) a request for a contested case hearing is pending. Otherwise, the Commissioner will make the decision. Persons who submit comments or petitions to the MPCA must state (1) their interest in the permit application or the draft permit; (2) the action'they wish the MPCA to take, including specific references to the section of the draft permit they believe should be changed; and (3) the reasons supporting their position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position. As described in Minn. R. 7000.1800, persons who submit requests for a contested case hearing must also state the issues they propose to address in a contested case hearing, the specific relief requested or resolution of the matter, and the reasons (which may be in the form of proposed findings) supporting an MPCA decision to hold a contested case hearing. Failure to comply with these rules exactly may.result in a denial of the request. The decision whether to hold a contested case hearing will be made under Minn. R. 7000.1906. Most public libraries throughout the state have copies of the current Minnesota Rules. They are also available the Internet at www.revisor.lee.state.mn.us Mercury Single All Pollutant PM PMlq PM2,5 S0 2 NO, VOCs CO Lead (Ib /yr) HAP HAPs Total Facility 20.1 20.1 20.1 95 209 40.2 67.0 0.125 15.0 27.9 35.4 Limited PTE PM = Particulate Matter NO, _ Nitrogen Oxides PM PM smaller than 10 microns S0 = Sulfur Dioxide PM = PM smaller than 2.5 microns VOCs = Volatile Organic Compounds CO = Carbon Monoxide HAP = Hazardous Air Pollutant The Permittee has submitted a pollution prevention progress report pursuant to Minn. Stat. § 115D.08. The preliminary determination to issue the permits is tentative. There are four formal procedures for public participation in the MPCA's consideration of the permit application. Interested persons may (1) submit written comments on the draft /proposed permit; (2) request that the MPCA hold a public information meeting; (3) request the MPCA hold a contested case hearing; and /or (4) submit a petition'to the Commissioner requesting that the MPCA Citizens' Board (Board) consider the permit matter. The decision whether to issue the permits and, if so, under what terms, will be presented to the Board for decision if: (1) the Commissioner grants the petition requesting the matter be presented to the Board; (2) an Board member requests to hear the matter prior to the time the Commissioner makes a final decision on the permit; or (3) a request for a contested case hearing is pending. Otherwise, the Commissioner will make the decision. Persons who submit comments or petitions to the MPCA must state (1) their interest in the permit application or the draft permit; (2) the action'they wish the MPCA to take, including specific references to the section of the draft permit they believe should be changed; and (3) the reasons supporting their position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position. As described in Minn. R. 7000.1800, persons who submit requests for a contested case hearing must also state the issues they propose to address in a contested case hearing, the specific relief requested or resolution of the matter, and the reasons (which may be in the form of proposed findings) supporting an MPCA decision to hold a contested case hearing. Failure to comply with these rules exactly may.result in a denial of the request. The decision whether to hold a contested case hearing will be made under Minn. R. 7000.1906. Most public libraries throughout the state have copies of the current Minnesota Rules. They are also available the Internet at www.revisor.lee.state.mn.us The public comment period commences March 7, 2012, and terminates April 23, 2012. Comments must be received by e -mail or in writing at the MPCA by 4:30 p.m. on April 23, 2012. evidence of timely receipt includes adate /time stamp imprinted on the first page of the written comments by first floor informQtion and reception area of the MPCA or by the Industrial Division support staff, or receipt by fax or email. Comments, requests, and petitions on either permit should be sent to the appropriate individual listed below:' Hazardous Waste Facility Permit -Air Permit Greg Kvaal, Land and Air Compliance Section Trevor Shearen, P.E „Air Quality Permits Section Industrial Division, Minnesota Pollution Control Agency Industrial Division, Minnesota Pollution Control Agency 520 Lafayette Road North, St. Paul_, Minnesota 55155 520 Lafayette Road North, St. Paul, Minnesota 55155 651- 757 -2511— Voice, 651 -296 -8717 — Fax 651 -757 -2717 = Voice, 651296_ -8717 Fax grett.kvaal @state.mn.us trevor.shearen@state.mn.us A copy of the draft /proposed permits will be available on the MPCA's webste at http: / /www.oca.state.mn.us /news /data /index.cfm ?PN =1, or will also be mailed to any interested person_upon the MPCA's receipt of awritten request. Additional materials relating to the issuance of these permits are available for inspection by appointment at the Minnesota Pollution Control Agency, 520 Lafayette Road North, St:,Paul, Minnesota 55155, phone 651- 757 -2623, between the hours of 8A0 a.m. and 4:30 p.m., Monday through Friday. All MPCA offices maybe reached by calling 800- 657 -3864. In addition, a copy of the draft/proposed permits and supporting documents are available for public inspection and copying at the Park Grove Branch Library, 7900 Hemingway Avenue South, Cottage Grove, Minnesota. After the close of the public notice period, all comments and requests for a contested ease hearing will be reviewed. A final determination about the reissuance of the Hazardous Waste Facility Permit and Air Permit will be made at that time. A formal response to comments received will be prepared in accordance with MPCA rules. Notification of the permit decision will be provided to each person who submitted written or oral comments or requested a notice of decision. DATED: Februar 28, Jeff Connell, Manager Don Smith, P.E., Manager Land and Air Compliance Section Air Quality Permits Section Industrial Division Industrial Division Draft/Proposed AIR EMISSION PERMIT NO. 16300025 -002 IS ISSUED TO 3M Co 3M - Cottage Grove Corporate Incinerator 10746 Innovation Rd Cottage Grove, Washington County, MN 55016 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Issue Date Action Total Facility Operating Permit Reissuance August 18, 2009 See Below 002 Major Amendment February 5, 2009 This permit amendment supersedes Air Emission Permit No. 16300025 -002 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Part 70/Limits to Avoid NSR Issuance Date: Expiration: Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): 651- 282 -5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Appendices Appendix A: Table 1 to Subpart EEE of Part 63 — General Provisions Applicable to Subpart EEE Appendix B: Table 2 to Subpart DD of Part 63 — General Provisions Applicable to Subpart DD Appendix C: Insignificant Activities and General Applicable Requirements NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency's (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651- 296 -6300 Outside Metro Area 1- 800 - 657 -3864 TTY 651- 282 -5332 The rules governing these programs are contained in Minn. R. chs. 7000 -7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155 -4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0 100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: The 3M Company (Permittee) Cottage Grove Center (Facility) is located at 10746 Innovation Road, Cottage Grove, Minnesota. 3M has operated the thermal treatment system under a combined air quality and hazardous waste permit. For purposes of simplifying the permit situation, this permit is an air permit only. The facility also has a separate RCRA hazardous waste permit. The 3M Corporate Incinerator provides treatment and storage of hazardous waste generated by 3M's operating divisions throughout North America, high BTU liquid solvent waste from outside sources, and regulated hazardous waste from Minnesota law- enforcement agencies. The Incineration system is designed to handle a variety of wastes introduced through four separate feed systems. Materials can be fed to the rotary kiln by four means depending on the waste stream. Solids are fed through a bulk feed chute (pakfeeder and Komar shredder); pumpable liquids are fed through lances or the frontwall burner; sludge is fed through a lance from either the Building 145 sludge room or the Building 47 pump room; and direct burn wastes are fed through a lance. The system consists of a rotary kiln and a secondary combustion chamber (SCC) followed by a wet off -gas cleaning system. The off - gas cleaning system consists of a quench chamber, a subcooler, a particulate removal device known as the Ml module, a wet electrostatic precipitator (WESP), an induced draft fan, and an exhaust stack. Hazardous waste is shipped to the Facility via semi - trailers in 55- gallon steel drums, totes, plastic and fiber drums, pails, boxes, bags, portable tanks, and tanker trucks. The types of containerized wastes received include solids, gases in cylinders, pumpable sludges, organic liquids, and aqueous liquids. Located at this Facility are indoor and outdoor container storage areas, outdoor tank storage areas, a containment building for bulk solids storage, a tanker truck unloading area, outdoor trailer storage, indoor and outdoor material handling areas, and a rotary kiln incinerator with a secondary combustion chamber. These units provide treatment and storage of hazardous waste generated by 3M's operating divisions. No disposal of hazardous waste is conducted at this Facility. This permit authorizes the operation of the combustion system consisting of a rotary kiln and a secondary combustion chamber. The rotary kiln is 40 feet long, has a shell diameter of 14 feet 9 inches, and is designed as a primary combustion chamber. The SCC is 60 feet high and has a shell diameter of 20 feet. It provides additional residence time to combust off -gases of organic wastes. The SCC burners have been removed, and the burner inlets are welded shut welded shut, which has reduced the overall capacity of the incinerator. An emergency vent stack is provided at the roof of the secondary combustion chamber. The combustion system has no boiler. This permit does not authorize the installation of a future boiler. Pollution control is facilitated with several flue gas treatment devices. The incinerator exhaust gases are saturated and cooled in the quench chamber. Flue gases then pass through a subcooling tower and filtering module. Final pollution control is provided by a wet electrostatic precipitator. Flue gases are pulled through the system with an induced draft fan and exhausted through a 165 - foot stack to the atmosphere. AMENDMENT DESCRIPTION: This permit amendment is a reissuance of the operating permit, and a major amendment to allow additional sources of non -3M hazardous waste for incineration in the kiln. The additional outside sources will provide high Btu value liquid solvent waste. The facility will also be authorized to process regulated hazardous waste from Minnesota law- enforcement agencies. TABLE A: LIMITS AND OTHER REQUIREMENTS A -1 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do Why to do it SOURCE - SPECIFIC REQUIREMENTS hdr The facility currently manages ozone - depleting substances as defined in 40 CFR 40 CFR pt. 82 pt. 82. Sections 601 -618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections 601 -618 and 40 CFR pt. 82 to determine all the requirements that apply to your facility. OPERATIONAL REQUIREMENTS hdr The Permittee shall comply with National Primary and Secondary Ambient Air 40 CFR pt. 50; Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Minn. Stat. Section 116.07, subds. 4a & 9; Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); upon written request by the MPCA. Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010- 7009.0080 Permit Appendices: This permit contains appendices as listed in the Table of Minn. R. 7007.0800, subp. 2 Contents. The Permittee shall comply with all requirements contained in the appendices. Circumvention: Do not install or use a device or means that conceals or dilutes Minn. R. 7011.0020 emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever Minn. R. 7007.0800, subps. 2 & 16(J) the corresponding process equipment and emission units are operated. Operation and Maintenance (O &M) Plan: Retain at the stationary source an O &M Minn. R. 7007.0800, subps. 14 & 16(J) plan for all air pollution control equipment. At a minimum, the O &M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall Minn. R. 7019.1000, subp. 4 immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, transporting, Minn. R. 7011.0150 or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Noise: The Permittee shall comply with the noise standards set forth in Minn. R. Minn. R. 7030.0010 - 7030.0080 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and Minn. R. 7007.0800, subp. 9(A) requirements as found in Minn. R. 7007.0800, subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R. Minn. R. 7007.0800, subp. 16 7007.0800, subp. 16. MONITORING REQUIREMENTS hdr Monitoring Equipment Calibration: Annually calibrate all required monitoring Minn. R. 7007.0800, subp. 4(D) equipment, not to exceed 12 months from the previous calibration. Operation of Monitoring Equipment: Unless otherwise noted in Table A, monitoring Minn. R. 7007.0800, subp. 4(D) a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. TABLE A: LIMITS AND OTHER REQUIREMENTS A -2 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 PERFORMANCE TESTING hdr Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 Minn. R. ch. 7017 unless otherwise noted in Table A. Performance Test Notifications and Submittals: Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1 -4; Performance Tests are due as outlined in Table A of the permit. Minn. R. 7017.2035, subps. 1 -2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre -test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Limits set as a result of a performance test (conducted before or after permit Minn. R. 7017.2025 issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. If a new limit is required to be set, it shall be based on the average of the test run averages during the stack test, unless otherwise specified in an applicable requirement. RECORDKEEPING hdr Recordkeeping: Retain all records at the stationary source for a period of five (5) Minn. R. 7007.0800, subp. 5(C) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as Minn. R. 7007.0800, subp. 5(B) required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. If the Permittee determines that no permit amendment or notification is required Minn. R. 7007.1200, subp. 4 prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING /SUBMITTALS hdr Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a Minn. R. 7019.1000, subp. 3 planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the Permittee does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown Minn. R. 7019.1000, subp. 2 of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24 -hour time period starts when the breakdown was discovered or reasonably should have been discovered by the Permittee. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 A -3 03/06/12 Notification of Deviations Endangering Human Health or the Environment: Minn. R. 7019.1000, subp. 1; As soon as possible after discovery, notify the Commissioner or the state duty Minn. Stat. Section 116.061 officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R. 7019.1000, subp. 1 Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. The cause of the deviation; 2. The exact dates of the period of the deviation, if the deviation has been corrected; 3. Whether or not the deviation has been corrected; 4. The anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R. 7007.1150 - 7007.1500 application in accordance with the requirements of Minn. R. 7007.1150- 7007.1500. Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment Minn. R. 7007.1400, subp. 1(H) to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R. 7019.3000 - 7019.3100 permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095 The Permittee shall submit a Part 1 MACT application within 30 days of startup of 40 CFR 63.52(b)(1) & (e)(1) any 1120) affected source. The application shall meet the requirements of 40 CFR Section 63.53(a). The Permittee shall submit a Part 2 MACT application within 90 days of startup of any 1120) affected source. The application shall meet the requirements of 40 CFR Section 63.53(b). 1120) affected source is defined in 40 CFR Section 63.51. As of permit issuance, 1120) affected sources include industrial, commercial, and institutional boilers and process heaters; brick and structural clay products manufacturing; and clay ceramics manufacturing. TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 A-4 03/06/12 Subject Item: GP 001 Equipment Leaks Subject to Subpart V -National Emission Standards for Equipment Leaks Associated Items: EU 003 Waste Handling Via Sludge Pump EU 012 Flanges, Piping and Valves -Kiln Burner Trains What to do Why to do it The Permittee shall demonstrate compliance with the standards of Subpart V for 40 CFR 63.691(b)(1); each new and existing source as required in 40 CFR 61.05, except as provided 40 CFR 61.242 -1(a); in 40 CFR 61.243 and 61.244. Minn. R. 7011.9990 Compliance with subpart V will be determined by review of records, review of 40 CFR 61.242 -1(b); performance test results, and inspection using the methods and procedures Minn. R. 7011.9990 specified in 40 CFR 61.245. The Permittee may request a determination of alternative means of emission 40 CFR 61.242 -1(c) limitation to the requirements of 40 CFR 61.242 -2, 61.242 -3, 61.242 -5, 61.242 -6, 61.242 -7, 61.242 -8, 61.242 -9 and 61.242 -11 as provided in 40 CFR 61.244. If the Administrator makes a determination that a means of emission limitation is at least a permissible alternative to the above requirements, the Permittee shall comply with the requirements of that determination. Each piece of equipment to which subpart V applies shall be marked in such a 40 CFR 61.242 -1(d); manner that it can be distinquished readily from other pieces of equipment. Minn. R. 7011.9990 Equipment that is in vacuum service is excluded from the standards of this subpart 40 CFR 61.242 -1(e); if it is identified as required in 40 CFR 61.246(e)(5). Minn. R. 7011.9990 STANDARDS: 40 CFR 61.242 -2 -- PUMPS Each pump shall be monitored monthly to detect leaks by the methods specified 40 CFR 61.242 -2(a); in the Test Methods of this subpart, except as provided in 40 CFR 61.242 -1(c) and Minn. R. 7011.9990 40 CFR 61.242- 2(d) -(g). Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal. Leak Detection - A leak is detected when: 40 CFR 61.242 -2(b); - An instrument reading of 10,000 ppm or greater is measured; or Minn. R. 7011.9990 - If there are indications of liquids dripping from the pump seal. Leak Detection - Repairs: 40 CFR 61.242 -2(c); When a leak is detected, it shall be repaired as soon as practicable, but not Minn. R. 7011.9990 later than 15 calendar days after it is detected, except as provided by the Delay of Repair standard. - A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. Each pump equipped with a dual mechanical seal system that includes a barrier 40 CFR 61.242 -2(d); fluid system is exempt from the requirements of 40 CFR 61.242- 2(a) -(b), provided Minn. R. 7011.9990 the following requirements are met. 1. Each dual mechanical seal system is: - Operated with the barrier fluid at a pressure that is at all times greater than the pump stuffing box pressure; or - Equipped with a barrier fluid degassing reservoir that is routed to a process or fuel gas system; or - Equipped with a system that purges the barrier fluid into a process stream with zero VHAP emissions to atmosphere. 2. The barrier fluid is not in VHAP service and, if the pump is covered by (continued) standards under 40 CFR part 60, is not in VOC service. 3. Each barrier fluid system is equipped with a sensor that will detect failure of the seal system, the barrier fluid system, or both. 4. Each pump is checked by visual inspection each calendar week for (continued) indications of liquids dripping from the pump seal. If there are indications of liquid dripping from the pump seal at the time of the weekly inspection, the pump shall be monitored to determine the presence of VOC and VHAP in the barrier fluid as specified by the Test Methods. If the monitor reading (taking into account any background readings) indicates the presence of VHAP, a leak is detected. For the purpose of this paragraph, the monitor may be calibrated with VHAP, or may employ a gas chromatography column to limit the response of the monitor to VHAP, at the option of the Permittee. If an instrument reading of 10,000 ppm or greater (total VOC) is measured, a leak is detected. 5. Each sensor, as described in 3. above, is checked daily or is equipped with an audible alarm. TABLE A: LIMITS AND OTHER REQUIREMENTS A -5 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 6. The Permittee determines, based on design considerations and operating (continued) experience, criteria applicable to the presence and frequency of drips and to the sensor that indicates failure of the seal system, the barrier fluid system, or both. If indications of liquids dripping from the pump seal exceed the criteria established above, or if, based on the criteria established above, the sensor indicates failure of the seal system, the barrier fluid system, or both, a leak is detected. When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after it is detected, except as provided by the Delay of Repair standard. - A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. Any pump that is designated, as described in section 246(e)(2), for no detectable 40 CFR 61.242 -2(e); emissions, as indicated by an instrument reading of < 500 ppm above background, Minn. R. 7011.9990 is exempt from the requirements of sections 242 -2(a), (c) & (d) if the pump: Has no externally actuated shaft penetrating the pump housing; Is demonstrated to be operating with no detectable emissions, as indicated by an instrument reading of < 500 ppm above background, as measured by the method specified in paragraph (c) of the Test Methods; and - Is tested for compliance with these emissions initially upon designation, annually, and at other times requested by the Administrator. If any pump is equipped with a closed -vent system capable of capturing and 40 CFR 61.242 -2(f); transporting any leakage from the seal or seals to a process or fuel gas system, Minn. R. 7011.9990 it is exempt from the requirements of 40 CFR 61.242- 2(a) -(e). Any pump that is designated, as described in section 246(f)(1), as an unsafe -to- 40 CFR 61.242 -2(g); monitor pump is exempt from the monitoring and inspection requirements of Minn. R. 7011.9990 40 CFR 61.242 -2(a) and (d)(4) -(6) if the Permittee: - Demonstrates that the pump is unsafe -to- monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with 40 CFR 61.242 -2(a); and - Has a written plan that requires monitoring of the pump as frequently as practicable during safe -to- monitor times but not more frequently than the periodic monitoring schedule otherwise applicable, and repair of the equipment according to the procedures in 40 CFR 61.242 -2(c) if a leak is detected. Any pump that is located within the boundary of an unmanned plant site is exempt 40 CFR 61.242 -2(h); from the weekly visual inspection requirement of 40 CFR 61.242- 2(a)(2) and (d)(4), Minn. R. 7011.9990 and the daily requirements of 40 CFR 61.242- 2(d)(5), provided that each pump is visually inspected as often as practicable and at least monthly. STANDARDS: 40 CFR 61.242 -4 -- PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE Except during pressure releases, each pressure relief device in gas /vapor service 40 CFR 61.242 -4(a); shall be operated with no detectable emissions, as indicated by an instrument Minn. R. 7011.9990 reading of less than 500 ppm above background, as measured by the method specified in paragraph (c) of the Test Methods. After each pressure release, the pressure relief device shall be returned to a 40 CFR 61.242 -4(b); condition of no detectable emissions, as indicated by an instrument reading of Minn. R. 7011.9990 less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided by the Delay of Repair standard. No later than 5 calendar days after the pressure release, the pressure relief device shall be monitored to confirm the condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as measured by the method specified in paragraph (c) of the Test Methods. Any pressure relief device that is routed to a process or fuel gas system or 40 CFR 61.242 -4(c); equipped with a closed -vent system capable of capturing and transporting leakage Minn. R. 7011.9990 from the pressure relief device to a control device as described in 40 CFR 61.242 -11 is exempt from the requirements of 40 CFR 61.242- 4(a) -(b). Any pressure relief device that is equipped with a rupture disk upstream of the 40 CFR 61.242 -4(d); pressure relief device is exempt from the requirements of 40 CFR 61.242- 4(a) -(b), Minn. R. 7011.9990 provided the Permittee complies with the following requirement: - After each pressure release, a new rupture disk shall be installed upstream of the pressure relief device as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in the Delay or Repair standard. STANDARDS: 40 CFR 61.242 -5 -- SAMPLING CONNECTING SYSTEMS TABLE A: LIMITS AND OTHER REQUIREMENTS A -6 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Each sampling connection system shall be equipped with a closed - purge, closed- 40 CFR 61.242 -5(a); loop, or closed vent system, except as provided in 40 CFR 61.242 -1(c). Gases Minn. R. 7011.9990 displaced during filling of the sample container are not required to be collected or captured. Each closed - purge, closed -loop, or closed vent system as required above shall 40 CFR 61.242 -5(b); comply with the following requirements: Minn. R. 7011.9990 1. Return the purged process fluid directly to the process line; or 2. Collect and recycle the purged process fluid; or 3. Be designed and operated to capture and transport all the purged process fluid to a control device that complies with the requirements of 40 CFR 61.242 -11; or 4. Collect, store, and transport the purged process fluid to any of the following (continued) systems or facilities: - A waste management unit as defined in 40 CFR 63.111 if the waste management unit is subject to and operated in compliance with the provisions of 40 CFR part 63, subpart G, applicable to Group 1 wastewater streams; or - A treatment, storage, or disposal facility subject to regulation under 40 CFR part 262, 264, 265, or 266; or - A facility permitted, licensed, or registered by a State to manage municipal or industrial solid waste, if the process fluids are not hazardous waste as defined in 40 CFR part 261. In -situ sampling systems and sampling systems without purges are exempt 40 CFR 61.242 -5(c); from the requirements of 40 CFR 61.242- 5(a) -(b). Minn. R. 7011.9990 STANDARDS: 40 CFR 61.242 -6 -- OPEN -ENDED VALVES OR LINES Each open -ended valve or line shall be equipped with a cap, blind flange, plug, 40 CFR 61.242 -6(a); or a second valve, except as provided in 40 CFR 61.242 -1(c). The cap, blind Minn. R. 7011.9990 flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open -ended valve or line. Each open -ended valve or line equipped with a second valve shall be operated in a 40 CFR 61.242 -6(b); manner such that the valve on the process fluid end is closed before the second Minn. R. 7011.9990 valve is closed. When a double block and bleed system is being used, the bleed valve or line 40 CFR 61.242 -6(c); may remain open during operations that require venting the line between the Minn. R. 7011.9990 block valves but shall comply with 40 CFR 61.242 -6(a) at all other times. The following are exempt from the requirements of 40 CFR 61.242- 6(a) -(c): 40 CFR 61.242- 6(d) -(e); - Open -ended valves or lines in an emergency shutdown system which are Minn. R. 7011.9990 designed to open automatically in the event of a process upset. - Open -ended valves or lines containing materials which would autocatalytically polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and bleed system as specified in 40 CFR 61.242- 6(a) -(c). STANDARDS: 40 CFR 61.242 -7 -- VALVES Each valve shall be monitored monthly to detect leaks by the method specified 40 CFR 61.242 -7(a); in the Test Methods of this subpart and shall comply with the leak detection Minn. R. 7011.9990 requirements below. Exceptions are provided in paragraphs (f) -(h), and the alternative standards in section 243 and section 242 -1(c). Leak Detection - A leak is detected when: 40 CFR 61.242 -7(b); - An instrument reading of 10,000 ppm or greater is measured. Minn. R. 7011.9990 Leak Detection - Monitoring: 40 CFR 61.242 -7(c); - Any valve for which a leak is not detected for 2 successive months may be Minn. R. 7011.9990 monitored the first month of every quarter, beginning with the next quarter, until a leak is detected. - If a leak is detected, the valve shall be monitored monthly until a leak is not detected for 2 successive months. Leak Detection - Repairs: 40 CFR 61.242- 7(d) -(e); - When a leak is detected, it shall be repaired as soon as practicable, but no Minn. R. 7011.9990 later than 15 calendar days after the leak is detected, except as provided in the Delay of Repair section of this subpart. - A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. First attempts at repair include, but are not limited to, the following best practices where practicable: - Tightening of bonnet bolts; - Replacement of bonnet bolts; - Tightening of packing gland nuts; and - Injection of lubricant into lubricated packing. TABLE A: LIMITS AND OTHER REQUIREMENTS A -7 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Any valve that is designated, as described in section 246(e)(2), for no detectable 40 CFR 61.242 -7(f); emissions, as indicated by an instrument reading of less than 500 ppm above Minn. R. 7011.9990 background, is exempt from the requirements of 40 CFR 61.242 -7(a) if the valve: - Has no external actuating mechanism in contact with the process fluid; - Is operated with emissions less than 500 ppm above background, as measured by the method specified in the test methods of this subpart; and - Is tested for compliance with these emissions initially upon designation, annually, and at other times requested by the Administrator. Any valve that is designated, as described in section 246(f)(1), as an unsafe -to- 40 CFR 61.242 -7(g); monitor valve is exempt from the requirements of 40 CFR 61.242 -7(a) if: Minn. R. 7011.9990 - The Permittee demonstrates that the valve is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with 40 CFR 61.242 -7(a); and - The Permittee has a written plan that requires monitoring of the valve as frequent as practicable during safe -to- monitor times. Any valve that is designated, as described in section 246(f)(2), as a difficult -to- 40 CFR 61.242 -7(h); monitor valve is exempt from the requirements of 40 CFR 61.242 -7(a) if: Minn. R. 7011.9990 - The Permittee demonstrates that the valve cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface; - The process unit within which the valve is located is an existing process unit; and - The Permittee follows a written plan that requires monitoring of the valve at least once per calendar year. ALTERNATIVE STANDARDS FOR VALVES IN VHAP SERVICE 40 CFR 61.243 -1 -- Allowable Percentage of Valves Leaking The Permittee may elect to have all valves within a process unit to comply with an 40 CFR 61.243 -1(a); allowable percentage of valves leaking of equal to or less than 2.0 percent. Minn. R. 7011.9990 The following requirements shall be met if the Permittee decides to comply with an 40 CFR 61.243 -1(b); allowable percentage of valves leaking: Minn. R. 7011.9990 The Permittee must notify the Administrator that the Permittee has elected to have all valves within a process unit to comply with the allowable percentage of valves leaking before implementing this alternative standard, as specified in 40 CFR 61.247(d). - A performance test as specified below shall be conducted initially upon designation, annually, and at other times requested by the Administrator. - If a valve leak is detected, it shall be repaired in accordance with the Leak Detection standards above. Performance tests shall be conducted in the following manner: 40 CFR 61.243 -1(c); - All valves in VHAP service within the process unit shall be monitored within Minn. R. 7011.9990 1 week by the methods specified in the Test Methods of this subpart. - If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. - The leak percentage shall be determined by dividing the number of valves in VHAP service for which leaks are detected by the number of valves in VHAP service within the process unit. Permittees who elect to have all valves comply with this alternative standard shall 40 CFR 61.243 -1(d); not have a process unit with a leak percentage greater than 2.0 percent. Minn. R. 7011.9990 If the Permittee decides no longer to comply with the Allowable Percentage of 40 CFR 61.243 -1(e); Valves Leaking Standard in 40 CFR 61.243 -1, the Permittee must notify the Minn. R. 7011.9990 Administrator in writing that the work practice standard described in 40 CFR 61.242- 7(a) -(e) will be followed. ALTERNATIVE STANDARDS FOR VALVES IN VHAP SERVICE 40 CFR 61.243 -2 -- Skip Period Leak Detection and Repair The Permittee may elect for all valves within a process unit to comply with one of 40 CFR 61.243 -2(a); the alternative work practices specified in the next requirement. Minn. R. 7011.9990 The Permittee must notify the Administrator before implementing one of the alternative work practices, as specified in 40 CFR 61.247(d). TABLE A: LIMITS AND OTHER REQUIREMENTS A -8 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 The Permittee shall comply initially with the requirements for valves, as described 40 CFR 61.243 -2(b); in 40 CFR 61.242 -7. Minn. R. 7011.9990 1. After 2 consecutive quarterly leak detection periods with the percentage of valves leaking equal to or less than 2.0, the Permittee may begin to skip one of the quarterly leak detection periods for the valves in VHAP service; or 2. After five consecutive quarterly leak detection periods with the percentage of valves leaking equal to or less than 2.0, the Permittee may begin to skip three of the quarterly leak detection periods for the valves in VHAP service. If the percentage of valves leaking is greater than 2.0, the Permittee shall comply with the requirements as described in 40 CFR 61.242 -7 but may again elect to use this section. STANDARDS: 40 CFR 61.242 -8 -- PRESSURE RELIEF SERVICES IN LIQUID SERVICE AND CONNECTORS If evidence of a potential leak is found by visual, audible, olfactory, or any other 40 CFR 61.242 -8(a); detection method at pressure relief devices in liquid service and connectors, the Minn. R. 7011.9990 Permittee shall follow either one of the following procedures, except as provided in 40 CFR 61.242 -1(c): The Permittee shall monitor the equipment within 5 days by the method specified in 40 CFR 61.245(b) and shall comply with the requirements of Leak Detection and repair requirements of this section; or The Permittee shall eliminate the visual, audible, olfactory, or other indication of a potential leak. Leak Detection - A leak is detected when: 40 CFR 61.242 -8(b); - An instrument reading of 10,000 ppm or greater is measured. Minn. R. 7011.9990 Leak Detection - Repairs: 40 CFR 61.242- 8(c) -(d); - When a leak is detected, it shall be repaired as soon as practicable, but not Minn. R. 7011.9990 later than 15 calendar days after it is detected, except as provided by the Delay of Repair standard. - The first attempt at repair shall be made no later than 5 calendar days after each leak is detected. First attempts at repair include, but are not limited to, the following best practices where practicable: - Tightening of bonnet bolts; - Replacement of bonnet bolts; - Tightening of packing gland nuts; and - Injection of lubricant into lubricated packing. STANDARDS: 40 CFR 61.242 -10 -- DELAY OF REPAIR Delay of repair of equipment for which leaks have been detected will be allowed 40 CFR 61.242- 10(a); if repair within 15 days is technically infeasible without a process unit shutdown. Minn. R. 7011.9990 Repair of this equipment shall occur before the end of the next process unit shutdown. Delay of repair of equipment for which leaks have been detected will be allowed 40 CFR 61.242- 10(b); for equipment that is isolated from the process and that does not remain in VHAP Minn. R. 7011.9990 service. Delay of repair for valves will be allowed if: 40 CFR 61.242- 10(c); The Permittee demonstrates that emissions of purged material resulting from Minn. R. 7011.9990 immediate repair are greater than the fugitive emissions likely to result from delay of repair, and - When repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR 61.242 -11. Delay of repair for pumps will be allowed if: 40 CFR 61.242- 10(d); - Repair requires the use of a dual mechanical seal system that includes Minn. R. 7011.9990 a barrier fluid system, and - Repair is completed as soon as practicable, but not later than 6 months after the leak was detected. Delay of repair beyond a process unit shutdown will be allowed for a valve if valve 40 CFR 61.242- 10(e); assembly replacement is necessary during the process unit shutdown, valve Minn. R. 7011.9990 assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. ALTERNATIVE MEANS OF EMISSION LIMITATION 40 CFR 61.244 Permission to use an alternative means of emission limitation under section 40 CFR 61.244(a) 112(e)(3) of the Clean Air Act shall be governed by the following procedures: TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 A -9 03/06/12 1. Where the standard is an equipment, design, or operational requirement: 40 CFR 61.244(b) - The Permittee who applyies for permission shall be responsible for collecting and verifying test data for an alternative means of emission limitation to test data for the equipment, design, and operational requirements. - The Administrator may condition the permission on requirements that may be necessary to assure operation and maintenance to achieve the same emission reduction as the equipment, design, and operational requirements. 2. Where the standard is a work practice: 40 CFR 61.244(c) - The Permittee shall be responsible for collecting and verifying test data for an alternative means of emission limitation. - For each source the emission reduction achieved by the required work practices shall be demonstrated for a minimum period of 12 months. - For each source the emission reduction achieved by the alternative means of emission limitation shall be demonstrated. - The Permittee shall commit in writing each source to work practices that provide for emission reductions equal to or greater than the emission reductions achieved by the required work practices. - The Administrator will compare the demonstrated emission reduction for (continued) the alternative means of emission limitation to the demonstrated emission reduction for the required work practices and will consider the commitment in 40 CFR 61.244(c)(4). - The Administrator may condition the permission on requirements that may be necessary to assure operation and maintenance to achieve the same emission reduction as the required work practices of subpart V. 3. The Permittee may offer a unique approach to demonstrate the alternative 40 CFR 61.244(d) means of emission limitation. 4. Manufacturers of equipment used to control equipment leaks of a VHAP may 40 CFR 61.244(e) apply to the Administrator for permission for an alternative means of emission limitation that achieves a reduction in emissions of the VHAP achieved by the equipment, design, and operational requirements of subpart V. The Administrator will grant permission according to the provisions of 40 CFR 61.244(b) -(d). TEST METHODS AND PROCEDURES 40 CFR 61.245 The Permittee shall use the test methods and procedures listed in 40 CFR 61.245 40 CFR 61.245; for determining compliance with subpart V. Minn. R. 7011.9990 Each piece of equipment within a process unit that can conceivably contain 40 CFR 61.245(d)(1); equipment in VHAP service is presumed to be in VHAP service unless the Minn. R. 7011.9990 Permittee demonstrates that the piece of equipment is not in VHAP service. For a piece of equipment to be considered not in VHAP service, it must be determined that the percent VHAP content can be reasonably expected never to exceed 10% by weight. For purposes of determining the percent VHAP content of the process fluid that is contained in or contacts equipment, procedures that conform to the methods described in ASTM Method D -2267 shall be used. The Permittee may use engineering judgment rather than the procedures in 40 CFR 61.245(d)(2); 40 CFR 61.245(d)(1) to demonstrate that the percent VHAP content does not Minn. R. 7011.9990 exceed 10% by weight, provided that the engineering judgment demonstrates that the VHAP content clearly does not exceed 10% by weight. When the Permittee and the Administrator do not agree on whether a piece of equipment is not in VHAP service, however, the procedures in 40 CFR 61.245(d)(1) shall be used to resolve the disagreement. If the Permittee determines that a piece of equipment is in VHAP service, the determination can be revised only after following the procedures in 40 CFR 61.245(d)(1). Samples used in determining the percent VHAP content shall be representative of 40 CFR 61.245(d)(3); the process fluid that is contained in or contacts the equipment or the gas being Minn. R. 7011.9990 combusted in the flare. RECORDKEEPING REQUIREMENTS 40 CFR 61.246 The Permittee may use one recordkeeping system which identifies each record 40 CFR 61.246(a)(2); by each process unit to comply with the requirements of all units subject to this Minn. R. 7011.9990 subpart. When each leak is detected as specified in GP 001, the following apply: 40 CFR 61.246(b); - A weatherproof and readily visible identification, marked with the equipment Minn. R. 7011.9990 identification number, shall be attached to the leaking equipment. - The identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR 61.242 -7(c) and no leak has been detected during those 2 months. - The identification on equipment, except on a valve, may be removed after it has been repaired. TABLE A: LIMITS AND OTHER REQUIREMENTS A -10 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 When each leak is detected as specified in GP 001, the following information shall 40 CFR 61.246(c); be recorded in a log and shall be kept for 2 years in a readily accessible location: Minn. R. 7011.9990 The instrument, operator, and equipment identification numbers. The date the leak was detected and the dates of each attempt to repair the leak. Repair methods applied in each attempt to repair the leak. "Above 10,000" if the maximum instrument reading measured by the methods specified in the Test Methods standard after each repair attempt is equal to or greater than 10,000 ppm. "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. The signature of the designate whose decision it was that repair could not be (continued) effected without a process shutdown. The expected date of successful repair of the leak if a leak is not repaired within 15 calendar days. - Dates of process unit shutdowns that occur while the equipment is unrepaired. The date of successful repair of the leak. For all equipment to which a standard applies, the following information shall be 40 CFR 61.246(e); recorded in a log that is kept readily accessible: Minn. R. 7011.9990 1. A list of identification numbers for equipment (except welded fittings) subject to the requirements of subpart V. 2. A list of identification numbers for equipment that the Permittee elects to designate for no detectable emissions as indicated by an instrument reading of less than 500 ppm above background. The designation of this equipment for no detectable emissions shall be signed by the Permittee. 3. A list of equipment identification numbers for pressure relief devices complying with 40 CFR 61.242 -4(a). 4. The dates of each compliance test required in GP 001. - The background level measured during each compliance test. - The maximum instrument reading measured at the equipment during each compliance test. 5. A list of identification numbers for equipment in vacuum service. The following information pertaining to all valves subject to the requirements of 40 CFR 61.246(f); 40 CFR 61.242- 7(g) &(h) (unsafe - /difficult -to- monitor) and to all pumps subject to Minn. R. 7011.9990 the requirements of 40 CFR 61.242 -2(g) (unsafe -to- monitor) shall be recorded in a log that is kept in a readily accessible location: A list of identification numbers for valves and pumps that are designated as unsafe to monitor, an explanation for each valve or pump stating why the valve or pump is unsafe to monitor, and the plan for monitoring each valve or pump. - A list of identification numbers for valves that are designated as difficult to monitor, an explanation for each valve stating why the valve is difficult to monitor, and the planned schedule for monitoring each valve. The following information shall be recorded for valves complying with 40 CFR 61.246(g); 40 CFR 61.243 -2 (skip period leak detection and repair): Minn. R. 7011.9990 - A schedule of monitoring. - The percent of valves found leaking during each monitoring period. The following information shall be recorded in a log that is kept in a readily 40 CFR 61.246(h); accessible location: Minn. R. 7011.9990 Design criterion required in 40 CFR 61.242 -2(d), and an explanation of the design criterion; and - Any changes to this criterion and the reasons for the changes. The following information shall be recorded in a log that is kept in a readily 40 CFR 61.246(i); accessible location for use in determining exemptions as provided in the Minn. R. 7011.9990 applicability section of subpart V and other specific subparts: - An analysis demonstrating the design capacity of the process unit, and - An analysis demonstrating that equipment is not in VHAP service. Information and data used to demonstrate that a piece of equipment is not in VHAP 40 CFR 61.2460); service shall be recorded in a log that is kept in a readily accessible location. Minn. R. 7011.9990 REPORTING REQUIREMENTS 40 CFR 61.247 The Permittee shall submit a statement in writing notifying the Administrator that 40 CFR 61.247(a)(1); the requirements of 40 CFR 61.242, 61.245, 61.246, and 61.247 are being Minn. R. 7011.9990 implemented for any piece of equipment to which subpart V applies. This statement shall be submitted with the application for approval of construction and shall contain the following information for each source: Equipment identification number and process unit identification. - Type of equipment (for example, a pump or pipeline valve). - Percent by weight VHAP in the fluid at the equipment. Process fluid state at the equipment (gas /vapor or liquid). Method of compliance with the standard (for example, "monthly leak detection and repair" or "equipped with dual mechanical seals "). TABLE A: LIMITS AND OTHER REQUIREMENTS A -11 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 A report shall be submitted to the Administrator semiannually that includes the 40 CFR 61.247(b); following information: Minn. R. 7011.9990 1. Process unit identification. 2. For each month during the semiannual reporting period, report the number of: Valves for which leaks were detected as described in 40 CFR 61.242 -7(b) or 40 CFR 61.243 -2; Valves for which leaks were not repaired as required in 40 CFR 61.242 -7(d). Pumps for which leaks were detected as described in 40 CFR 61.242- 2(b) &(d)(6). Pumps for which leaks were not repaired as required in 40 CFR 61.242- 2(c) &(d)(6). Number of compressors for which leaks were detected as described in (continued) 40 CFR 61.242 -3(f). Number of compressors for which leaks were not repaired as required in 40 CFR 61.242 -3(g). The facts that explain any delay of repairs and, where appropriate, why a process unit shutdown was technically infeasible. 3. Dates of process unit shutdowns which occurred within the semiannual reporting period. 4. Revisions to items reported according to 40 CFR 61.247(a) if changes have occurred since the initial report or subsequent revisions to the initial report. 5. The results of all performance tests and monitoring to determine compliance with no detectable emissions and with CFR 61.243 -1 & 61.243 -2 conducted within the semiannual reporting period. The semiannual reports shall be submitted according to the schedule specified 40 CFR 61.247(c); in the initial report, unless_ a revised schedule has been submitted in a previous Minn. R. 7011.9990 semiannual report. If the Permittee elects to comply with the provisions of 40 CFR 61.243 -1 and 40 CFR 61.247(d); 61.243 -2 (alternative standards for valves), the Permittee shall notify the Minn. R. 7011.9990 Administrator of the alternative standard selected 90 days before implementing either of the provisions. An application for approval of construction or modification, 40 CFR 61.05(a) and 40 CFR 61.247(e); 61.07, will not be required if: Minn. R. 7011.9990 - The new source complies with the standard, 40 CFR 61.242; - The new source is not part of the construction of a process unit; and - In the next semiannual report required by 40 CFR 61.247(b) the information in 40 CFR 61.247(a)(5) is reported. TABLE A: LIMITS AND OTHER REQUIREMENTS A -12 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: GP 002 Containers Subject to Subpart PP - National Emission Standards for Containers Associated Items: EU 004 Waste Handling Via Drum Handling EU 005 Pump Room Drum Handling What to do Why to do it These requirements pertain to the control of air emissions from containers which 40 CFR 63.920; require Level 1 or 2 controls as required by 40 CFR 63.688. Minn. R. 7011.7400, subp. C STANDARDS 40 CFR 63.922 -- Container Level 1 Controls A container using Container Level 1 controls is one of the following: 40 CFR 63.922(b) 1. A container that meets the applicable U.S. Department of Transportation (DOT) (40 CFR 63.922(b)(1)); regulations on packaging hazardous materials for transportation as specified in Minn. R. 7011.7400, subp. C 40 CFR 63.922(f). 2. A container equipped with a cover and closure devices that form a continuous (continued) barrier over the container openings such that when the cover and closure devices (40 CFR 63.922(b)(2) &(3)); are secured in the closed position there are no visible holes, gaps, or other open Minn. R. 7011.7400, subp. C spaces into the interior of the container. The cover may be a separate cover installed on the container (e.g., a lid on a drum, a suitably secured tarp on a roll -off box) or may be an integral part of the container structural design. 3. An open -top container in which an organic vapor- suppressing barrier is placed on or over the regulated - material in the container such that no regulated - material is exposed to the atmosphere. A container used to meet the requirements of either 40 CFR 63.922(b)(2) or (b)(3) 40 CFR 63.922(c); shall be equipped with covers and closure devices, as applicable to the container, Minn. R. 7011.7400, subp. C that are composed of suitable materials to minimize exposure of the regulated material to the atmosphere and to maintain the equipment integrity for as long as it is in service. Factors to be considered when selecting the materials for and designing the cover and closure devices shall include: organic vapor permeability, the effects of contact with the material or its vapor managed in the container; the effects of outdoor exposure to wind, moisture, and sunlight; and the operating practices used for the container on which the cover is installed. STANDARDS 40 CFR 63.923 -- Container Level 2 Controls A container using Container Level 2 controls is one of the following: 40 CFR 63.923(b); 1. A container that meets the applicable U.S. DOT regulations on packaging Minn. R. 7011.7400, subp. C hazardous materials for transportation as specified in 40 CFR 63.923(f). 2. A container that has been demonstrated to operate with no detectable organic emissions as defined in 40 CFR 63.921. 3. A container that has been demonstrated within the preceeding 12 months to be vapor -tight by using Method 27 in Appendix A of 40 CFR part 60 in accordance with the proceedure specified in 40 CFR 63.925(b). Transfer of regulated - material in to or out of a container using Container Level 2 40 CFR 63.923(c); controls shall be conducted in such a manner as to minimize exposure of the Minn. R. 7011.7400, subp. C regulated - material to the atmosphere, to the extent practical, considering the physical properties of the regulated - material and good engineering and safety practices for handling flammable, ignitable, explosive, or other hazardous materials. COVERS AND CLOSURE DEVICES hdr Whenever a regulated - material is in a container using Container Level 1 or 2 40 CFR 63.922(d); controls, install all covers and closure devices for the container, and secure 40 CFR 63.923(d); and maintain each closure device in the closed position except as follows: Minn. R. 7011.7400, subp. C 1. Opening of a closure device or cover is allowed for the purpose of adding material to the container as follows: - In the case when the container is filled to the intended final level in one continuous operation, the Permittee shall promptly secure the closure devices in the closed position and install the covers, as applicable to the container, upon conclusion of the filling operation. - In the case when discrete quantities or batches of material intermittently are (continued) added to the container over a period of time, the Permittee shall promptly (40 CFR 63.922(d)(1)(ii); secure the closure devices in the closed position and install covers, as 40 CFR 63.923(d)(1)(11)); applicable to the container, upon either: the container being filled to the Minn. R. 7011.7400, subp. C intended final level; the completion of a batch loading after which no additional material will be added to the container within 15 minutes; the person performing the loading operation leaves the immediate vicinity of the container; or the shutdown of the process generating the material being added to the container, whichever condition occurs first. TABLE A: LIMITS AND OTHER REQUIREMENTS A -13 03/06112 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 2. Opening of a closure device or cover is allowed for the purpose of removing (continued) material from the container in the case when discrete quantities or batches of (40 CFR 63.922(d)(2); material are removed from the container. The Permittee shall promptly secure 40 CFR 63.923(d)(2)); the closure devices in the closed position and install covers, as applicable to Minn. R. 7011.7400, subp. C the container, upon the completion of a batch removal after which no additional material will be removed from the container within 15 minutes, or the person performing the unloading operation leaves the immediate vicinity of the container, whichever condition occurs first. An empty container as defined in 40 CFR 63.921 may be open to the atmosphere at any time (e.g., covers and closure devices are not required to be secured in the closed position on an empty container). 3. Opening of a closure device or cover is allowed when access inside the (continued) container is needed to perform routine activities other than transfer of regulated- (40 CFR 63.922(d)(3); material. Upon completion of the activity, the Permittee shall promptly secure 40 CFR 63.923(d)(3)); the closure device in the closed position or reinstall the cover, as applicable to Minn. R. 7011.7400, subp. C the container. 4. Opening of a spring - loaded pressure- vacuum relief valve, conservation vent, or (continued) similar type of pressure relief device which vents to the atmosphere is allowed (40 CFR 63.922(d)(4); during normal operations for the purpose of maintaining the container internal 40 CFR 63.923(d)(4)); pressure in accordance with the container design specifications. Minn. R. 7011.7400, subp. C The device shall be designed to operate with no detectable organic emissions when the device is secured in the closed position. The settings at which the device opens shall be established such that the device remains in the closed position whenever the container internal pressure is within the internal pressure operating range determined by the Permittee based on container manufacturer recommendations, applicable regulations, fire protection and prevention codes, standard engineering codes and practices, or other requirements for the safe handling of flammable, ignitable, explosive, reactive, or hazardous materials. 5. Opening of a safety device, as defined in 40 CFR 63.921, is allowed at any (continued) time conditions require it to do so to avoid an unsafe condition. (40 CFR 63.922(d)(5); 40 CFR 63.923(d)(5)); Minn. R. 7011.7400, subp. C A container that meets the applicable U.S. DOT regulations on packaging 40 CFR 63.922(0; hazardous materials for transportation shall meet the following requirements: 40 CFR 63.923(0; 1. The container must meet the applicable requirements specified in 49 CFR 178 Minn. R. 7011.7400, subp. C -- Specifications for Packagings or 49 CFR 179 -- Specifications for Tank Cars. 2. Regulated - material must be managed in the container in accordance with the applicable requirements specified in 49 CFR 107(8) -- Exemptions; and 49 CFR 172, 173, & 180. 3. No exceptions to the regulations of 49 CFR part 178 or part 179 are allowed; except, for a lab pack that is managed in accordance with the requirements of 49 CFR 178, the Permittee may comply with the exceptions for those packagings specified in 49 CFR 173.12(b). INSPECTION AND MONITORING REQUIREMENTS 40 CFR 63.926 The Permittee shall inspect the containers and their cover and closure devices 40 CFR 63.922(e) & 63.923(e); according to the following requirements: 40 CFR 63.926(a); Minn. R. 7011.7400, subp. C 1. When a regulated - material already is in the container at the time the Permittee 40 CFR 63.926(a)(1); first accepts possession of the container and the container is not emptied within Minn. R. 7011.7400, subp. C 24 hours after the container has been accepted at the facility site, the container and its cover and closure devices shall be visually inspected by the Permittee to check for visible cracks, holes, gaps, or other open spaces into the interior of the container when the cover and closure devices are secured in the closed position. This inspection of the container must be conducted on or before the date that the container is accepted at the facility (i.e., the date that the container becomes subject to the standards under subpart PP). The date of acceptance is the date of signature of the Permittee on the manifest or shipping papers accompanying the container. 2. When a container filled or partially filled with regulated - material remains 40 CFR 63.926(a)(2); unopened at the facility site for a period of 1 year or more, the container and its Minn. R. 7011.7400, subp. C cover and closure devices shall be visually inspected by the Permittee initially and thereafter, at least once every calendar year, to check for visible cracks, holes, gaps, or other open spaces into the interior of the container when the cover and closure devices are secured in the closed position. 3 When a defect is detected for the container, cover, or closure devices, the 40 CFR 63.926(a)(3); Permittee must either empty the regulated - material from the defective container Minn. R. 7011.7400, subp. C or repair the defective container in accordance with the following requirements: TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 A -14 03106/12 - To empty the regulated - material from the defective container, remove the (continued) regulated - material from the defective container to meet the conditions for an empty container and transfer the removed regulated - material to either a container that meets the applicable standards under subpart PP or to a tank, process, or treatment unit that meets the applicable standards. Transfer of the regulated - material must be completed no later than 5 calendar days after detection of the defect. The emptied defective container must be either repaired, destroyed, or used for purposes other than management of regulated - material. If the Permittee elects not to empty the regulated - material from the defective (continued) container, the Permittee must repair the defective container. First efforts at repair of the defect must be made no later than 24 hours after detection and repair must be completed as soon as possible but no later than 5 calendar days after detection. If repair of a defect cannot be completed within 5 calendar days, then the regulated - material must be emptied from the container and the container must not be used to manage regulated - material until the defect is repaired. TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: GP 003 Tanks Subject to Subpart 00 - National Emission Standards for Tanks Associated Items: TK 007 Waste Solvent - Tank 3 (Overflow Tank) TK 012 #2 Fuel Oil - Tank 12 TK 014 Waste Solvent - Tank 11 TK 015 Decant TK 016 Sludge Blend Tank TK 017 Sludge Feed Tank TK 018 Waste Solvent - Tank 21 TK 019 Waste Solvent - Tank 22 TK 020 Waste Solvent - Tank 23 TK 021 Waste Solvent - Tank 24 TK 022 Waste Solvent - Tank 25 TK 023 Waste Solvent - Tank 26 TK 024 Waste Solvent - Tank 27 TK 025 Waste Solvent - Tank 28 A -15 03/06/12 What to do Why to do it STANDARDS 40 CFR 63.902 -- Tank Fixed Roof This section applies to the control of air emissions from a tank using a fixed roof, 40 CFR 63.902(a); that is not also equipped with an internal floating roof. Minn. R. 7011.7400, subp. B Each tank shall be equipped with a fixed roof designed to meet the following: 40 CFR 63.902(b); 1. The fixed roof and its closure devices shall be designed to form a continuous Minn. R. 7011.7400, subp. B barrier over the entire surface area of the liquid in the tank. The fixed roof may be a separate cover installed on the tank or may be an integral part of the tank structural design. 2. The fixed roof shall be installed in a manner such that there are no visible cracks, holes, gaps, or other open spaces between roof section joints or between the interface of the roof edge and the tank wall. 3. Each opening in the fixed roof, and any manifold system associated with the (continued) fixed roof, shall be either: - equipped with a closure device designed to operate such that when the closure device is secured in the closed position there are no visible cracks, holes, gaps, or other open spaces in the closure device or between the perimeter of the opening and the closure device; or - connected by a closed -vent system that is vented to a control device. The control device shall remove or destroy organics in the vent stream, and shall be operating whenever regulated material is managed in the tank. 4. The fixed roof and its closure devices shall be made of suitable materials that (continued) will minimize exposure of the regulated - material to the atmosphere, to the extent practical, and will maintain the integrity of the equipment throughout its intended service life. Factors to be considered when selecting the materials for and designing the fixed roof and closure devices shall include: organic vapor permeability, the effects of any contact with the liquid or its vapors managed in the tank; the effects of outdoor exposure to wind, moisture, and sunlight; and the operating practices used for the tank on which the fixed roof is installed. Whenever a regulated - material is in the tank, the fixed roof shall be installed with 40 CFR 63.902(c); each closure device secured in the closed position except as follows: Minn. R. 7011.7400, subp. B 1. Opening of closure devices or removal of the fixed roof is allowed only: - To provide access to the tank for performing routine inspection, maintenance, or other activities needed for normal operations. Following completion of the activity, the Permittee shall promptly secure the closure device in the closed position or reinstall the cover, as applicable, to the tank. - To remove accumulated sludge or other residues from the bottom of the tank. TABLE A: LIMITS AND OTHER REQUIREMENTS A -16 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 2. Opening of a spring - loaded pressure- vacuum relief valve, conservation vent, or (continued) similar type of pressure relief device which vents to the atmosphere is allowed during normal operations for the purpose of maintaining the tank internal pressure in accordance with the tank design specifications. The device shall be designed to operate with no detectable organic emissions when the device is secured in the closed position. The settings at which the device opens shall be established such that the device remains in the closed position whenever the tank internal pressure is within the internal pressure operating range determined by the Permittee based on the tank manufacturer recommendations, applicable regulations, fire protection and prevention codes, standard engineering codes (continued) and practices, or other requirements for the safe handling of flammable, combustible, explosive, reactive, or hazardous materials. 3. Opening of a safety device, as defined in 40 CFR 63.901 is allowed at any time conditions require it to do so to avoid an unsafe condition. The Permittee shall inspect the air emission control equipment in accordance with 40 CFR 63.902(d); the requirements specified in 40 CFR 63.906(a). Minn. R. 7011.7400, subp. B TEST METHODS AND PROCEDURES 40 CFR 63.905 The Permittee shall use the test methods and procedures listed in 40 CFR 63.905 40 CFR 63.905; for determining no detectable organic emissions to determine compliance with Minn. R. 7011.7400, subp. B subpart DD. INSPECTION AND MONITORING REQUIREMENTS 40 CFR 63.906 Each tank listed in GP 003 shall be inspected to meet the following requirements: 40 CFR 63.906(a); 1. The fixed roof and its closure devices shall be visually inspected by the Minn. R. 7011.7400, subp. B Permittee to check for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in the roof sections or between the roof and the tank wall; broken, cracked, or otherwise damaged seals or gaskets on closure devices; and broken or missing hatches, access covers, caps, or other closure devices. 2. Perform an initial inspection following installation of the fixed roof. Perform (continued) subsequent inspections at least once every calendar year except as provided under 40 CFR 63.906(d). 3. Maintain a record of the inspection in accordance with the recordkeeping requirements of GP 003. The Permittee shall repair all detected defects as follows: 40 CFR 63.906(a)(3) &(b); 1. First efforts at repair of the defect shall be made no later than 5 calendar days Minn. R. 7011.7400, subp. B after detection and repair shall be completed as soon as possible but no later than 45 calendar days after detection except as provided below. 2. Repair of a defect may be delayed beyond 45 calendar days if the Permittee determines that repair of the defect requires emptying or temporary removal from service of the tank and no alternative tank capacity is available at the site to accept the regulated material normally managed in the tank. In this case, the Permittee shall repair the defect the next time alternative tank capacity becomes available and the tank can be emptied or temporarily removed from service, as necessary to complete the repair. The Permittee shall maintain a record of the defect repair in accordance with the 40 CFR 63.906(c); recordkeeping requirements of GP 003. Minn. R. 7011.7400, subp. B Alternative Inspection and Monitoring Interval. 40 CFR 63.906(d); Following the initial inspection and monitoring of a fixed roof, subsequent Minn. R. 7011.7400, subp. B inspection and monitoring of the equipment may be performed at intervals longer than 1 year when the Permittee determines that performing the required inspection or monitoring procedures would expose a worker to dangerous, hazardous, or otherwise unsafe conditions and complies with the following requirements: 1. Prepare and maintain at the plant site written documentation identifying the specific air pollution control equipment designated as "unsafe to inspect and monitor." The documentation must include for each piece of air pollution control equipment designated as such a written explanation of the reasons why the equipment is unsafe to inspect or monitor using the applicable procedures under 40 CFR 63.906. 2. The Permittee must develop and implement a written plan and schedule to (continued) inspect and monitor the fixed roof and its closure devices using the applicable procedures specified in 40 CFR 63.906 during times when a worker can safely access the equipment. The required inspections and monitoring must be performed as frequently as practicable but do not need to be performed more frequently than the periodic schedule that would be otherwise applicable to the equipment under the provisions of 40 CFR 63.906. A copy of the written plan and schedule must be maintained at the plant site. RECORDKEEPING REQUIREMENTS 40 CFR 63.907 TABLE A: LIMITS AND OTHER REQUIREMENTS A -17 03106/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Prepare and maintain a record for each tank that includes the following information: 40 CFR 63.907(a); 1. A tank identification number (or other unique identification description). Minn. R. 7011.7400, subp. B 2. A description of the tank dimensions and the tank design capacity. 3. The date that each inspection required by 40 CFR 63.906 is performed. The Permittee shall record the following information for each defect detected during 40 CFR 63.907(b); inspections required by 40 CFR 63.906: Minn. R. 7011.7400, subp. B The location of the defect; A description of the defect; - The date of detection; and The corrective action taken to repair the defect; and If applicable, the reason for delay of repair and expected repair completion date. TABLE A: LIMITS AND OTHER REQUIREMENTS A -18 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: GP 004 Tanks Subject to Subpart DD - NESHAP from Off -Site Waste and Recovery Operations Associated Items: CE 012 Flaring TK 002 Hazardous Waste Solvent What to do Why to do it APPLICABILITY AND DESIGNATION OF AFFECTED SOURCES 40 CFR 63.680 An off -site material management unit is a tank, container, surface impoundment, 40 cfr 63.680(b)(1)(ii) &(c)(1); oil -water separator, organic -water separator, or transfer system used to manage Minn. R. 7011.7400, subp. A off -site material. Each off -site material management unit is subject to Subpart DD. Any material that is a waste, used oil, or used solvent that is produced or generated within the plant site is not an off -site material subject to Subpart DD. STANDARDS: 40 CFR 63.685 -- Tanks TK 002 shall be vented through a closed -vent system to a control device in 40 CFR 63.685(b)(1), (d) &(g); accordance with the following requirements: Minn. R. 7011.7400, subp. A 1. The tank shall be covered by a fixed roof and vented directly through a closed - vent system to a control device in accordance with the following requirements: The fixed roof and its closure devices shall be designed to form a continuous barrier over the entire surface area of the liquid in the tank. Each opening in the fixed roof not vented to the control device shall be (continued) equipped with a closure device. If the pressure in the vapor headspace underneath the fixed roof is less than atmospheric pressure when the control device is operating, the closure devices shall be designed to operate such that when the closure device is secured in the closed position there are no visible cracks, holes, gaps, or other open spaces in the closure device or between the perimeter of the cover opening and the closure device. If the pressure in the vapor headspace underneath the fixed roof is equal to or greater than atmospheric pressure when the control device is operating, the closure device shall be designed to operate with no detectable organic emissions. - The fixed roof and its closure devices shall be made of suitable materials that (continued) will minimize exposure of the off -site material to the atmosphere, to the extent practical, and will maintain the integrity of the equipment throughout its intended service life. Factors to be considered when selecting the materials for and designing the fixed roof and closure devices shall include: organic vapor permeability, the effects of any contact with the liquid and its vapor managed in the tank; the effects of outdoor exposure to wind, moisture, and sunlight; and the operating practices used for the tank on which the fixed roof is installed. - The closed -vent system and control device shall be designed and operated in accordance with 40 CFR 63.693. 2. The fixed roof shall be installed with each closure device secured in the closed (continued) position and the vapor headspace underneath the fixed roof vented to the control device except as follows: - Venting to the control device is not required, and opening of closure devices or removal of the fixed roof is allowed at the following times: a. To provide access to the tank for performing routine inspection, maintenance, or other activities needed for normal operations. Following completion of the activity, the Permittee shall promptly secure the closure device in the closed position or reinstall the cover, as applicable, to the tank; or b. To remove accumulated sludge or other residues from the bottom of the tank. - Opening of a safety device is allowed at any time conditions require it to do so to avoid an unsafe condition. 3. The Permittee shall inspect and monitor the air emission control equipment in (continued) accordance with the Inspection and Monitoring requirements of GP 004. STANDARDS 40 CFR 63.688; -- Containers Minn. R. 7011.7400, subp. A The Permittee shall control air emissions from containers in accordance with the 40 CFR 63.688(b); standards for Container Level 2 controls, except that containers with a design Minn. R. 7011.7400, subp. A capacity greater than 0.1 cubic meters and less than 0.46 cubic meters may be controlled using the standards for Container Level 1 controls, listed under GP 002. Control air emissions for each transfer system by using one of the following: 40 CFR 63.689; 1. A transfer system that uses covers in accordance with 40 CFR 63.689(d); Minn. R. 7011.7400, subp. A 2. A transfer system that consists of continuous hard piping. All joints or seams between the pipe sections shall be permanently or semi - permanently sealed; or TABLE A: LIMITS AND OTHER REQUIREMENTS A -19 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 3. A transfer system that is enclosed and vented through a closed vent system to (continued) a control device such that: The transfer system is designed and operated such that the internal pressure in the vapor headspace in the enclosure is maintained at a level less than atmospheric pressure when the control device is operating, and The closed -vent system and control device are designed and operated in accordance with 40 CFR 63.693. STANDARDS: 40 CFR 63.693 -- Closed -Vent Systems and Control Devices The vent stream required to be controlled shall be conveyed to the flare by a 40 CFR 63.693(b)(1) &(c); closed -vent system that is designed to operate with no detectable organic Minn. R. 7011.7400, subp. A emissions using the procedure specified in 40 CFR 63.694(k). The Permittee shall use a flare that meets the following requirements: 40 CFR 63.693(b)(2) &(5); 1. The flare must be designed and operated in accordance with the requirements 40 CDR 63.693(h); in 40 CFR 63.11(b). Demonstrate this by performing the following procedures: Minn. R. 7011.7400, subp. A Conduct a visible emission test for the flare according to 40 CFR 63.11(b)(4). - Determine the net heating value of the gas being combusted in the flare according to 40 CFR 63.11(b)(6); and Determine the flare exit velocity in accordance with the requirements applicable to the flare design as specified in 40 CFR 63.11(b)(7) or (b)(8). A previous compliance demonstration for the flare may be used to demonstrate compliance with this requirement by meeting the following conditions: The compliance determination was conducted using the above procedures; and - No flare operating parameter or process changes have occurred since completion of the compliance determination which could affect the results. 2. Monitor the operation of the flare using a heat sensing monitoring device that (continued) continuously detects the presence of a pilot flame. Record, for each 1 -hour period, whether the monitor was continuously operating and whether a pilot flame was continuously present during each hour. The flare shall be operating whenever gases or vapors containing HAP are vented 40 CFR 63.693(b)(3); to the flair except as listed below: Minn. R. 7011.7400, subp. A - The flare may be bypassed for the purpose of performing planned routine maintenance of the closed -vent system or flare in situations when the routine maintenance cannot be performed during periods that the tank vented to the flare is shutdown. On an annual basis, the total time that the closed -vent system or flare is bypassed to perform routine maintenance shall not exceed 240 hours per each calendar year. - The flare may be bypassed for the purpose of correcting a malfunction of the closed -vent system or flare. The Permittee shall perform the adjustments or repairs necessary to correct the malfunction as soon as practicable after the malfunction is detected. TESTING METHODS AND PROCEDURES 40 CFR 63.694 The Permittee shall use the test methods and procedures listed in 40 CFR 40 CFR 63.694(k); 63.694(k) for determining no detectable organic emissions to determine Minn. R. 7011.7400, subp. A compliance with subpart DD. INSPECTION AND MONITORING REQUIREMENTS 40 CFR 63.695(b) -- Tanks Each tank listed in GP 004 shall be inspected to meet the following requirements: 40 CFR 63.695(a)(1) &(b)(3); 1. The fixed roof and its closure devices shall be visually inspected by the Minn. R. 7011.7400, subp. A Permittee to check for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in the roof sections or between the roof and the tank wall; broken, cracked, or otherwise damaged seals or gaskets on closure devices; and broken or missing hatches, access covers, caps, or other closure devices. 2. Perform an initial inspection following installation of the fixed roof. Perform (continued) subsequent inspections at least once every calendar year except as provided under Alternative Inspection and Monitoring Interval. 3. Maintain a record of the inspection in accordance with the recordkeeping requirements of GP 004. TABLE A: LIMITS AND OTHER REQUIREMENTS A -20 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Repair all detected defects as follows: 40 CFR 63.695(a)(1), (b)(3)(iii) &(b)(4); 1. Within 45 calendar days of detecting the defect either repair the defect or empty Minn. R. 7011.7400, subp. A the tank and remove it from service. If within this 45 -day period the defect cannot be repaired or the tank cannot be removed from service without disrupting operations at the plant site, the Permittee is allowed two 30 -day extensions. If the Permittee elects to use a 30 -day extension, prepare and maintain documentation describing the defect, explaining why alternative storage capacity is not available, and specify a schedule of actions that will ensure that the control equipment will be repaired or the tank emptied as soon as possible. 2. When a defect is detected during an inspection of a tank that has been emptied and degassed, the Permittee shall repair the defect before refilling the tank. INSPECTION AND MONITORING REQUIREMENTS 40 CFR 63.695(c) -- Closed -Vent Systems Inspect and monitor the closed -vent systems using the following procedures: 40 CFR 63.693(b)(4)(i); 1. At initial startup, monitor the closed -vent system components and connections 40 CFR 63.695(a)(2) &(c); using the procedures specified in 40 CFR 63.694(k) to demonstrate that the Minn. R. 7011.7400, subp. A closed -vent system operates with no detectable organic emissions. 2. After initial startup, inspect and monitor the closed -vent system as follows: (continued) - Closed -vent system joints, seams, or other connections that are permanently or semi - permanently sealed shall be visually inspected at least once per year to check for defects that could result in air emissions. Monitor a component or connection using the procedures specified in 40 CFR 63.694(k) to demonstrate that it operates with no detectable organic emissions following any time the component is repaired or replaced or the connection is unsealed. - Closed -vent system components or connections other than those specified (continued) above shall be monitored at least once per year following 40 CFR 63.694(k) to demonstrate that components or connections operate with no detectable organic emissions. - The continuous monitoring system shall monitor and record either an instantaneous data value at least once every 15 minutes or an average value for intervals of 15 minutes or less. 3. The Permittee shall maintain a record of the inspection and monitoring in (continued) accordance with the recordkeeping requirements of GP 004. Repair all detected defects or leaks as follows: 40 CFR 63.695(c)(1)(iii) &(c)(3); 1. First efforts at repair of the defect shall be made no later than 5 calendar days Minn. R. 7011.7400, subp. A after detection and repair shall be completed as soon as possible but no later than 45 calendar days after detection. 2. Repair of a defect may be delayed beyond 45 calendar days if either of the (continued) following conditions occur: - Completion of the repair is technically infeasible without the shutdown of the unit that vents to the closed -vent system. - The Permittee determines that the air emissions resulting from the repair of the defect within the specified period would be greater than the fugitive emissions likely to result by delaying the repair until the next time the unit that vents to the closed -vent system is shutdown. Repair the defect the next time the unit that vents to the closed -vent system is shutdown, the repair must be completed before the unit resumes operation. 3. Maintain a record of the defect repair in accordance with the recordkeeping requirements of GP 004. RECORDKEEPING REQUIREMENTS 40 CFR 63.696 The Permittee shall comply with the recordkeeping requirements in 40 CFR 63.10 40 CFR 63.696(a); that are applicable to Subpart DD as specified in Appendix B of this permit. Minn. R. 7011.7400, subp. A Prepare and maintain a record for each tank that includes the following information: 40 CFR 63.696(e)(1); 1. A tank identification number (or other unique identification description). Minn. R. 7011.7400, subp. A 2. The date of inspection. For each defect detected during inspections, record the following information: 40 CFR 63.696(e)(2); The location and a description of the defect; Minn. R. 7011.7400, subp. A - The date of detection; and - Corrective action taken to repair the defect; and If applicable, the reason for delay of repair and expected repair completion date. TABLE A: LIMITS AND OTHER REQUIREMENTS A -21 03/06112 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Record, on a semiannual basis, the following information for those planned routine 40 CFR 63.696(g); maintenance operations that would require the flare not to meet the Closed -Vent Minn. R. 7011.7400, subp. A Systems and Control Devices Standards of GP 004: 1. A description of the planned routine maintenance that is anticipated to be performed for the flare during the next 6 months. This description shall include the type of maintenance necessary, planned frequency of maintenance, and lengths of maintenance periods; and 2. A description of the planned routine maintenance that was performed for the flare during the previous 6 months. This description shall include the type of maintenance performed and the total number of hours during these 6 months that the flare did not meet the the Closed -Vent Systems and Control Devices Standards of GP 004. Record the following information for those unexpected flare malfunctions that would 40 CFR 63.696(h); require the flare not to meet the Closed -Vent Systems and Control Devices Minn. R. 7011.7400, subp. A Standards of GP 004: 1. The occurrence and duration of each malfunction of the flare; 2. The duration of each period during a malfunction when gases, vapors, or fumes are vented from the waste management unit through the closed -vent system to the flare while the flare is not properly functioning. 3. Actions taken during periods of malfunction to restore a malfunctioning flare to its normal or usual manner of operation. REPORTING REQUIREMENTS 40 CFR 63.697 The Permittee must submit reports to the Administrator in accordance with the 40 CFR 63.697(a)(2); applicable reporting requirements in 40 CFR 63.10 as specified in Appendix B. Minn. R. 7011.7400, subp. A For the flare, submit the following notifications and reports to the Administrator: 40 CFR 63.697(b); 1. A Notification of Performance Tests specified in 40 CFR 63.7 and 63.9(g); Minn. R. 7011.7400, subp. A 2. Performance test reports specified in 40 CFR 63.10(d)(2); and 3. SSM reports specified in 40 CFR 63.10(d)(5). (continued) If actions taken during SSM are not completely consistent with the procedures specified in the source's SSM plan specified in 40 CFR 63.6(e)(3), the information shall be stated in the report. The report shall consist of a letter, containing the name, title, and signature of the responsible official who is certifying its accuracy, that shall be submitted to the Administrator, and Separate SSM reports are not required if the information is included in the summary report specified in 40 CFR 63.697(b)(4). 4. A summary report specified in 40 CFR 63.10(e)(3) shall be submitted on a semi- (continued) annual basis. The report must include a description of all excursions as defined in 40 CFR 63.695(e) that have occurred during the 6 -month reporting period. For each excursion caused when the daily average value of a monitored operating parameter is less than the minimum operating parameter limit, the report must include the daily average values of the monitored parameter, the applicable operating parameter limit, and the date and duration of the period that the exceedance occurred. For each excursion caused by lack of monitoring data, the report must include the date and duration of the period when the monitoring data were not collected and the reason why the data were not collected. TABLE A: LIMITS AND OTHER REQUIREMENTS A -22 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: EU 008 Replacement Rotating Kiln Associated Items: CE 004 Subcooling Vessel CE 005 M1 Module CE 010 Venturi Quench CE 011 Electrostatic Precipitator - High Efficiency MR 002 Stack CO MR 004 Stack 02 SV 010 Incinerator Stack SV 025 Incinerator Emergency Stack What to do Why to do it Table 1 to Subpart EEE of Part 63 identifies the General Provisions that are 40 CFR 63.1 to 63.15 applicable to Subpart EEE. Table 1 to Subpart EEE and a copy of the applicable portions of the General Provisions have been incorporated into this permit as a fully enforceable appendix to this permit. The acronyms used in these requirements refer to the following: 40 CFR 63.1201(b); CAS, Chemical Abstract Services registry Minn. R. 7011.7410 CEMS, Continuous, Emissions Monitoring System CMS, Continuous Monitoring System DRE, Destruction and Removal Efficiency MTEC, Maximum Theoretical Emissions Concentration DOC, Documentation of Compliance NOC, Notification of Compliance EMISSION LIMITS hdr Significant figures for emission limits. The Permittee must perform intermediate 40 CFR 63.1219(d); calculations using at least three significant figures, and may round the resultant Minn. R. 7011.7410 emission levels to two significant figures to document compliance. Dioxins and Furans: less than or equal to 0.40 ng TEQ /dscm corrected 40 CFR 63.1219(a)(1)(ii); to 7% oxygen. Minn. R. 7011.7410 Mercury: less than or equal to 33.0 micrograms /DSCM corrected to 7% oxygen. Minn. R. 7007.0800, subp. 2; The more stringent state limit assures compliance with the NESHAP limit of 40 CFR 63.1219(a)(2); 130 micrograms /dscm. Minn. R. 7011.7410 Mercury: less than or equal to 15.0 Ibs /year using 12 -month Rolling Sum Minn. R. 7007.0800, subp. 2 Semi - Volatile Metals - Pb, Cd: less than or equal to 230.0 micrograms /dscm, 40 CFR 63.1219(a)(3); combined emissions, corrected to 7% oxygen. Minn. R. 7011.7410 Low - Volatile Metals - As, Be, Cr: less than or equal to 92.0 micrograms /dscm, 40 CFR 63.1219(a)(4); combined emissions, corrected to 7% oxygen. Minn. R. 7011.7410 Carbon Monoxide: less than or equal to 100 parts per million by volume (ppmv), 40 CFR 63.1219(a)(5); using 1 -hour rolling average (monitored continuously with a CEMS), dry basis and Minn. R. 7011.7410 corrected to 7% oxygen. Document that, during the DRE test runs or their equivalent as provided by 40 CFR 63.1206(b)(7), hydrocarbons do not exceed 10 ppmv during those runs, using 1 -hour rolling average (monitored continuously with a CEMS), dry basis, corrected to 7% oxygen, and reported as propane; or Hydrocarbons: less than or equal to 10 ppmv, using 1 -hour rolling average (monitored continuously with a CEMS), dry basis, corrected to 7% oxygen, and reported as propane. Hydrochloric Acid and Chlorine Gas: less than or equal to 32 ppmv, combined 40 CFR 63.1219(a)(6); emissions, expressed as hydrochloric acid equivalents, dry basis and corrected Minn. R. 7011.7410 to 7% oxygen. Total Particulate Matter: less than or equal to 29.8 milligrams /DSCM (0.013 gr /dscf) 40 CFR 63.1219(a)(7); corrected to 7% oxygen. Minn. R. 7011.0515, subp. 1; Minn. R. 7011.7410 Total Particulate Matter: less than or equal to 0.045 grains /dry standard cubic foot Minn. R. 7011.0610, subp. 1 Opacity: less than or equal to 20.0 percent opacity Minn. R. 7011.0110 Sulfur Dioxide: less than or equal to 95.0 tons /year using 12 -month Rolling Sum Title I Condition: To avoid major source classification under 40 CFR 52.21 and Minn. R. 7007.3000 Nitrogen Oxides: less than or equal to 190 parts per million Title I Condition: To avoid major source classification under 40 CFR 52.21 and Minn. R. 7007.3000 TABLE A: LIMITS AND OTHER REQUIREMENTS A -23 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Carbon Monoxide: less than or equal to 94.6 tons/year using 12 -month Rolling Sum Title I Condition: To avoid major source classification under 40 CFR 52.21 and Minn. R. 7007.3000 Volatile Organic Compounds: less than or equal to 20 parts per million dry, Title I Condition: To avoid major source classification as THC, corrected to 7% oxygen. under 40 CFR 52.21 and Minn. R. 7007.3000 Principle Organic Hazardous Constituent (POHC): The Permittee must specify 40 CFR 63.1219(c)(3); one or more POHCs that are representative of the most difficult to destroy organic Minn. R. 7011.7410 compounds in the hazardous waste feedstream. This specification shall be based on the degree of difficulty of incineration of the organic constituents in the waste and on their concentration or mass in the waste feed, considering the results of the waste analyses or other data and information. 99.99% DRE. The Permittee must achieve a DRE of 99.99% for each POHC 40 CFR 63.1219(c)(1); designated above. Calculate DRE for each POHC from the following equation: Minn. R. 7011.7410 DRE = [1 - (Wout / Win)] x 100% Where: Win = mass feedrate of one POHC in a waste feedstream; and Wout = mass emission rate of the same POHC present in exhaust emissions prior to release to the atmosphere. Beryllium: less than or equal to 10.0 grams per 24 -hour period 40 CFR 61.32(a); Minn. R. 7011.9940, subp. A The Permittee must use a carbon monoxide CEMS to demonstrate and monitor 40 CFR 63.1209(a)(1)(i); compliance with the carbon monoxide and hydrocarbon standard under subpart Minn. R. 7011.7410 EEE. The Permittee must also use an oxygen CEMS to continuously correct the CO level to 7% Oxygen. The Permittee must install, calibrate, maintain, and operate a particulate matter 40 CFR 63.1209(a)(1)(iii); CEMS to demonstrate and monitor compliance with the PM standards under Minn. R. 7011.7410 subpart EEE. FEEDRATE LIMITS hdr Process Throughput: less than or equal to 21,800 Ibs /hour using 1 -Hour Rolling 40 CFR 63.1209(j)(3) &(k)(4); Average of total hazardous waste to the kiln, unless a new maximum process Minn. R. 7011.7410 throughput is required to be set pursuant to Minn. R. 7017.2025, subp. 3. Process Throughput: less than or equal to 14,800 Ibs /hour using 1 -Hour Rolling 40 CFR 63.12090)(3) &(k)(4); Average of total pumpable waste to the kiln, unless a new maximum process Minn. R. 7011.7410 throughput is required to be set pursuant to Minn. R. 7017.2025, subp. 3. " Pumpable" includes solvent plus sludge. Process Throughput: less than or equal to 300 Ibs /hour using 1 -Hour Rolling 40 CFR 63.12090)(3) &(k)(4); Average of total waste feed rate to the secondary combustion chamber (SCC), Minn. R. 7011.7410 unless a new maximum process throughput is required to be set pursuant to Minn. R. 7017.2025, subp. 3. Process Throughput: less than or equal to 3,410 Ibs /hour using 12 -Hour Rolling 40 CFR 63.1209(m)(3); Average of ash fed to the system, unless a new maximum process throughput is Minn. R. 7011.7410 required to be set pursuant to Minn. R. 7017.2025, subp. 3. Chlorine: less than or equal to 735 Ibs /hour using 12 -Hour Rolling Average fed to 40 CFR 63.1209(n)(4) &(o)(1)(i); the system, unless a new maximum chlorine throughput is required to be set Minn. R. 7011.7410 pursuant to Minn. R. 7017.2025, subp. 3. Mercury: less than or equal to 0.0040 Ibs /hour using 12 -Hour Rolling Average fed 40 CFR 63.1207(m)(1); to the system. 40 CFR 63.1209(I)(1)(i); Minn. R. 7011.7410 Semi - Volatile Metals (SVM) - Pb, Cd: less than or equal to 2.47 Ibs /hour combined, 40 CFR 63.1209(n)(2)(i), (ii) & (vii); using 12 -hour rolling average fed to the system, unless a new maximum SVM Minn. R. 7011.7410 throughput is required to be set pursuant to Minn. R. 7017.2025, subp. 3, using the minimum of the following: 1. The approved feedrate extrapolation level; 2. The MTEC calculated to demonstrate compliance with 40 CFR 63.1219(a)(3). Low - Volatile Metals (LVM) - As, Be, Cr: less than or equal to 12.0 Ibs /hr combined, 40 CFR 63.1209(n)(2)(i), (ii) & (vii); using 12 -hour rolling average fed to the system, unless a new maximum LVM Minn. R. 7011.7410 throughput is required to be set pursuant to Minn. R. 7017.2025, subp. 3, using the minimum of the following: 1. The approved feedrate extrapolation level; 2. The MTEC calculated to demonstrate compliance with 40 CFR 63.1219(a)(4). TABLE A: LIMITS AND OTHER REQUIREMENTS A -24 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Pumpable LVM: less than or equal to 10.0 Ibs /hr combined, using 12 -hour rolling 40 CFR 63.1209(n)(2)(i), (ii), (vi) & (vii); average fed to the system, unless a new maximum pumpable LVM throughput is Minn. R. 7011.7410 required to be set pursuant to Minn. R. 7017.2025, subp. 3, using the minimum of the following: 1. The approved feedrate extrapolation level; 2. The MTEC calculated to demonstrate compliance with 40 CFR 63.1219(a)(4). The burning of dioxin /furan- listed wastes F020, F021, F022, F023, F026, or F027 40 CFR 63.1219(c)(2); (see 40 CFR 261.31) is prohibited. Minn. R. 7011.7410 OPERATING LIMITS hdr Temperature: greater than or equal to 1760 degrees F using 1 -Hour Rolling 40 CFR 63.12090)(1) &(k)(2); Average for a minimum kiln exit gas temperature, unless a new minimum Minn. R. 7011.7410 temperature is required to be set pursuant to Minn. R. 7017.2025, subp. 3. The temperature measurement location shall be as documented in the test plans submitted under 40 CFR 63.1207(e). Temperature: greater than or equal to 1710 degrees F using 1 -Hour Rolling 40 CFR 63.1209(j)(1) &(k)(2); Average for a minimum SCC exit gas temperature, unless a new minimum SCC Minn. R. 7011.7410 exit gas temperature is required to be set pursuant to Minn. R. 7017.2025, subp. 3. The temperature measurement location shall be as documented in the test plans submitted under 40 CFR 63.1207(e). Air Flow Rate: less than or equal to 39,700 dry standard cubic feettminute using 40 CFR 63.12090)(2), (k)(3), (n)(5) & (o)(3)(v); 1 -Hour Rolling Average for a maximum flue gas flow rate, unless a new maximum Minn. R. 7011.7410 flow rate is required to be set pursuant to Minn. R. 7017.2025, subp. 3. Air Flow Rate: greater than or equal to 33,100 dry standard cubic feettminute using 40 CFR 63.1207(m)(1)(iii); 12 -Hour Rolling Average (937 dscm /min) as a minimum flue gas flow rate. Minn. R. 7011.7410 The Permittee shall maintain a minimum atomization pressure of 31 PSIG in the 40 CFR 63.12090)(4); burner and the lances using 1 -hour rolling average. Minn. R. 7011.7410 COMPLIANCE STANDARDS hdr Mercury Calculation and Recordkeeping: By the 15th day of each month, the Minn. R. 7007.0800, subps. 2, 4, 5,14 & 16(J) Permittee shall calculate and record the monthly mercury emissions for the previous 12 calendar months. The Permittee shall maintain a written record of the monthly mercury emission calculations. Hazardous waste is defined to not be in the combustion chamber when the 40 CFR 63.1201(a); hazardous waste feed to the combustor has been cut off for a period of time Minn. R. 7011.7410 not less than the hazardous waste residence time. The emission standards and operating requirements set forth in subpart EEE apply 40 CFR 63.1206(b)(1); at all times except during periods of startup, shutdown, and malfunction (SSM), and Minn. R. 7011.7410 when hazardous waste is not in the combustion chamber. The Permittee has elected to comply with the CO and hydrocarbon emissions 40 CFR 63.1206(b)(6); standards by documenting continuous compliance with the CO standard using Minn. R. 7011.7410 a CEMS and documenting compliance with the hydrocarbon standard during the DRE performance tests which show compliance with the DRE standards. Use the highest hourly rolling average hydrocarbon level achieved during the DRE test runs to document compliance with the hydrocarbon standard. Documenting Compliance With the Standards Based on Performance Testing: 40 CFR 63.1206(b)(12); Conduct a minimum of three runs of a performance test required under 40 CFR Minn. R. 7011.7410 63.1207 to document compliance with the emission standards of 40 CFR 63.1219. Document compliance with the DRE standard for each run of the comprehensive performance test individually. Document compliance with all other emission standards based on the arithmetic average of the emission results of each run. Document compliance with the DRE standard only once provided that the 40 CFR 63.1206(b)(7); Permittee does not modify the source after the DRE test in a manner that Minn. R. 7011.7410 could affect the ability of the source to achieve the DRE standard. Use any DRE test data that documents that the source achieves the required level of DRE provided: The Permittee has not modified the design or operation of the source in a manner that could effect the ability of the source to achieve the DRE standard since the DRE test was performed; and The DRE test data meet quality assurance objectives determined on a site - specific basis. Calculate the hazardous waste residence time and include the calculation in the 40 CFR 63.1206(b)(11); Performance Test Plan and the Operating Record. Minn. R. 7011.7410 Provide the hazardous waste residence time in each Notification of Compliance. TABLE A: LIMITS AND OTHER REQUIREMENTS A -25 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 If the Permittee plans to change the design, operation, or maintenance practices of 40 CFR 63.1206(b)(5)(i); the source in a manner that may adversely affect compliance with any emission Minn. R. 7011.7410 standard that is not monitored with a CEMS the Permittee must: 1. Notify the Administrator at least 60 days prior to the change, unless the Permittee documents circumstances that dictate that such prior notice is not reasonably feasible. The notification must include: A description of the changes and affected emission standards; and A comprehensive performance test schedule and test plan that will document compliance with the affected emission standard(s); 2. Conduct a comprehensive performance test to document compliance with (continued) the affected emission standards and establish operating parameter limits as required under 40 CFR 63.1209, and submit a NOC; and 3. After the change and prior to submitting the NOC, the Permittee must not burn hazardous waste for more than 720 hours and only for the purposes of pretesting or comprehensive performance testing; or The Permittee may petition the Administrator to obtain written approval to burn hazardous waste in the interim prior to submitting a NOC for purposes other than testing or pretesting. The Permittee must specify operating requirements, including limits on operating parameters, that the Permittee determines will ensure compliance with the emission standards of subpart EEE based on available information. The Administrator will review, modify as necessary, and approve if warranted the interim operating requirements. If the Permittee determines that a change will not adversely affect compliance with 40 CFR 63.1206(b)(5)(ii); the emission standards or operating requirements, the Permittee must document Minn. R. 7011.7410 the change in the operating record upon making such change. The Permittee must revise as necessary the performance test plan, DOC, NOC, and SSM plan to reflect these changes. OPERATING REQUIREMENTS hdr Operate only under the operating requirements specified in the DOC under 40 CFR 40 CFR 63.1206(c)(1); 63.1211(c) or the NOC under 40 CFR 63.12070), except during performance tests Minn. R. 7011.7410 under approved test plans according to 40 CFR 63.1207(e) -(g) or periods of SSM. The DOC and the NOC must contain operating requirements including, but not limited to, the operating requirements in 40 CFR 63.1206 and 40 CFR 63.1209. Failure to comply with the operating requirements is failure to ensure compliance with the emission standards of subpart EEE. Startup, Shutdown, and Malfunction Plan: 40 CFR 63.1206(c)(2)(i); The Permittee is subject to the SSM plan requirements of 40 CFR 63.6(e)(3). Minn. R. 7011.7410 If electing to comply with 40 CFR 270.235(a)(1)(iii), (a)(2)(iii), or (b)(1)(ii) to address 40 CFR 63.1206(c)(2)(ii); RCRA concerns to minimize emissions of toxic compounds from SSM events, then: Minn. R. 7011.7410 1. The SSM plan must include a description of potential causes of malfunctions, including releases from emergency safety vents, that may result in significant releases of HAPs, and actions the source is taking to minimize the frequency and severity of those malfunctions; and 2. Submit the SSM plan to the Administrator for review and approval. The (continued) Permittee is responsible for ensuring that any supplementary and additional information supporting the plan is submitted in a timely manner to enable the Administrator to consider whether to approve the plan. Neither the submittal of, nor the Administrator's failure to approve or disapprove of the plan, relieves the Permittee of the responsibility to comply with the provisions of this subpart. 3. The Permittee must request approval in writing from the Administrator within (continued) 5 days after making a change to the SSM plan that may significantly increase emissions of hazardous air pollutants. To request approval of such changes to the SSM plan, the Permittee must follow the procedures above for initial approval of the plan. Identify in the SSM Plan a projected oxygen correction factor based on normal 40 CFR 63.1206(c)(2)(iii); operations to use during periods of startup and shutdown. Minn. R. 7011.7410 Record the SSM Plan in the operating record. 40 CFR 63.1206(c)(2)(iv); Minn. R. 7011.7410 TABLE A: LIMITS AND OTHER REQUIREMENTS A -26 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Automatic waste feed cutoff ( AWFCO): Operate the hazardous waste combustor 40 CFR 63.1206(c)(3) with a functioning system that immediately and automatically cuts off the (40 CFR 63.1206(c)(3)(i)); hazardous waste feed, except as provided by 40 CFR 63.1206(c)(3)(viii): Minn. R. 7011.7410 1. When any of the following are exceeded: Operating parameter limits specified under 40 CFR 63.1209; an emission standard monitored by a CEMS; and the allowable combustion chamber pressure; 2. When the span value of any CMS detector, except a CEMS, is met or exceeded; 3. Upon malfunction of a CMS monitoring an operating parameter limit specified under 40 CFR 63.1209 or an emission level; or 4. When any component of the automatic waste feed cutoff system fails. Ducting of Combustion Gases: During an AWFCO, the Permittee must continue to (continued) duct combustion gases to the air pollution control system while hazardous waste (40 CFR 63.1206(c)(3)(ii)); remains in the combustion chamber. Minn. R. 7011.7410 Restarting Waste Feed: The Permittee must continue to monitor during the cutoff (continued) the operating parameters for which limits are established under 40 CFR 63.1209 (40 CFR 63.1206(c)(3)(iii)); and the emissions required under that section to be monitored by a CEMS, and Minn. R. 7011.7410 the Permittee must not restart the hazardous waste feed until the operating parameters and emission levels are within the specified limits. Failure of the AWFCO System: If the AWFCO system fails to automatically and (continued) immediately cutoff the flow of hazardous waste upon exceedance of a parameter (40 CFR 63.1206(c)(3)(iv)); required to be interlocked with the AWFCO, the Permittee has failed to comply with Minn. R. 7011.7410 the AWFCO requirements. If an equipment or other failure prevents immediate and automatic cutoff of the hazardous waste feed, cease feeding hazardous waste as soon as possible. Corrective Measures: If, after any AWFCO, there is an exceedance of an emission (continued) standard or operating requirement, the Permittee must investigate the cause of the (40 CFR 63.1206(c)(3)(v)); AWFCO, take appropriate corrective measures to minimize future AWFCOs, and Minn. R. 7011.7410 record the findings and corrective measures in the operating record. Excessive Exceedance Reporting: (continued) 1. For each set of 10 exceedances of an emission standard or operating (40 CFR 63.1206(c)(3)(vi)); requirement while hazardous waste remains in the combustion chamber during Minn. R. 7011.7410 a 60 -day block period, the Permittee must submit to the Administrator a written report within 5 calendar days of the 10th exceedance documenting the exceedances and results of the investigation and corrective measures taken. 2. On a case -by -case basis, the Administrator may require excessive exceedance reporting when fewer than 10 exceedances occur during a 60 -day block period. Testing: Test the AWFCO system and associated alarms at least weekly to verify (continued) operability, or at least monthly if the Permittee documents in the operating record (40 CFR 63.1206(c)(3)(vii)); that weekly inspections will unduly restrict or upset operations and that less Minn. R. 7011.7410 frequent inspection will be adequate. The Permittee must document and record AWFCO operability test procedures and results in the operating record. Ramping Down Waste Feed: The Permittee may ramp down the waste feedrate of (continued) pumpable hazardous waste over a period not to exceed one minute, except as (40 CFR 63.1206(c)(3)(viii)); specified below. If the Permittee ramps down the waste feed, document ramp Minn. R. 7011.7410 down procedures in the O &M Plan. The procedures must specify that the ramp down begins immediately upon initiation of AWFCO and the procedures must prescribe a bona fide ramping down. If an emission standard or operating limit is exceeded during the ramp down, the Permittee failed to comply with the emission standards or operating requirements of subpart EEE. - If the automatic waste feed cutoff is triggered by an exceedance of any of the following operating limits, the Permittee may not ramp down the waste feed cutoff: minimum combustion chamber temperature, maximum hazardous waste feedrate, or any hazardous waste firing system operating limits that may be established for the combustor. Compliance with AWFCO requirements during malfunctions. 40 CFR 63.1206(c)(2)(v)(A); The AWFCO requirements of 40 CFR 63.1206(c)(3) continue to apply, Minn. R. 7011.7410 except for 40 CFR 63.1206(c)(3)(v) -(vi). 1. During malfunctions, if a Subpart EEE emission standard monitored by a CEMS or COMs or operating limit specified under 40 CFR 63.1209 is exceeded, the AWFCO system must immediately and automatically cutoff the hazardous waste feed, except as provided by 40 CFR 63.1206(c)(3)(viii). If the malfunction itself prevents immediate and automatic cutoff of the hazardous waste feed, cease feeding hazardous waste as soon as possible. 2. An exceedance of an emission standard monitored by a CEMS or COMS or operating limit specified under 63.1209 is not a violation of this subpart if the Permittee takes the corrective measures prescribed in the SSM Plan. TABLE A: LIMITS AND OTHER REQUIREMENTS A -27 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 3. For each set of 10 exceedances of an emission standard or operating (continued) requirement while hazardous waste remains in the combustion chamber during a 60 -day block period, the Permittee must: - Within 45 days of the 10th exceedance, complete an investigation of the cause of each exceedance and evaluation of approaches to minimize the frequency, duration, and severity of each exceedance, and revise the SSM Plan as warranted by the evaluation to minimize the frequency, duration, and severity of each exceedance; and - Record the results of the investigation and evaluation in the operating record, and include a summary of the investigation and evaluation, and any changes to the SSM Plan, in the excess emissions report under 40 CFR 63.10(e)(3). Compliance with AFCWO requirements when burning hazardous waste during 40 CFR 63.1206(c)(2)(v)(B); startup and shutdown. Minn. R. 7011.7410 If hazardous waste is fed during startup or shutdown, waste feed restrictions and other appropriate operating conditions and limits must be included in the SSM plan. The operating limits must be interlocked with the AQCWO system, except for paragraphs (c)(3)(v) &(vi) above. The AWFCO system must immediately and automatically cutoff the hazardous waste feed if the operating limits are exceeded, except as provided by (c)(3)(viii). An exceedance of an emission standard or operating limit is not a violation if complying with the operating procedures prescribed in the SSM plan. Emergency Safety Vent (ESV) openings 40 CFR 63.1206(c)(4) 1. Failure to Meet Standards: If an ESV opens when hazardous waste remains in (40 CFR 63.1206(c)(4)(i)); the combustion chamber during an event other than a malfunction as defined in Minn. R. 7011.7410 the SSM Plan such that combustion gases are not treated as during the most recent comprehensive performance test, the Permittee must document in the operating record whether the unit remains in compliance with the emission standards of this subpart considering emissions during the ESV opening event. 2. ESV Operating Plan: Develop an ESV Operating Plan, comply with the (continued) operating plan, and keep the plan in the operating record. The ESV operating (40 CFR 63.1206(c)(4)(11)); plan must provide detailed procedures for rapidly stopping the waste feed, Minn. R. 7011.7410 shutting down the combustor, and maintaining temperature and negative pressure in the combustion chamber during the hazardous waste residence time, if feasible. The plan must include calculations and information and data documenting the effectiveness of the plan's procedures for ensuring that combustion chamber temperature and negative pressure are maintained as is reasonably feasible. 3. Corrective Measures: After any ESV opening that results in a failure to meet the (continued) emission standards, Investigate the cause of the ESV opening, take appropriate (40 CFR 63.1206(c)(4)(iii)); corrective measures to minimize such future ESV openings, and record the Minn. R. 7011.7410 findings and corrective measures in the operating record. 4. Reporting Requirements: The Permittee must submit to the Administrator a (continued) written report within 5 days of an ESV opening that results in failure to meet (40 CFR 63.1206(c)(4)(iv)); standards (as defined above) documenting the result of the investigation and Minn. R. 7011.7410 corrective measures taken. Combustion system leaks of HAPs must be controlled by: 40 CFR 63.1206(c)(5)(i); Keeping the combustion zone sealed to prevent combustion system leaks; or Minn. R. 7011.7410 Maintaining the maximum combustion zone pressure lower than ambient pressure using an instantaneous monitor; or - Upon prior written approval of the Administrator, an alternative means of control to provide control of combustion system leaks equivalent to maintenance of combustion zone pressure lower than ambient pressure, or other technique(s) which can be demonstrated to prevent fugitive emissions without use of instantaneous pressure limits. Specify in the performance test workplan and NOC the method that will be used to 40 CFR 63.1206(c)(5)(ii); control combustion system leaks. If the Permittee controls combustion system Minn. R. 7011.7410 leaks by maintaining the combustion zone pressure lower than ambient pressure using an instantaneous monitor, then also specify in the performance test workplan and NOC the monitoring and recording frequency of the pressure monitor, and specify how the monitoring approach will be integrated into the AWFCO system. TABLE A: LIMITS AND OTHER REQUIREMENTS A -28 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Operator Training and Certification: Establish training programs for all personnel 40 CFR 63.1206(c)(6) whose activities may reasonably be expected to directly affect emissions of HAPs (40 CFR 63.1206(c)(6)(i)); from the source. Such persons include, but are not limited to, chief facility Minn. R. 7011.7410 operators, control room operators, CMS operators, persons that sample and analyze feedstreams, persons that manage and charge feedstreams to the combustor, persons that operate emission control devices, and ash and waste handlers. Each training program shall be of a technical level commensurate with the person's job duties specified in the training manual. Each commensurate training program shall require an examination to be administered by the instructor at the end of the training course. Passing of this test shall be deemed the "certification" for personnel, except that, for control room operators, the training and certification program shall be as specified in 40 CFR 63.1206(c)(6)(iii). The Permittee must ensure that the source is operated and maintained at all times (continued) by persons who are trained and certified to perform these and any other duties that (40 CFR 63.1206(c)(6)(ii)); may affect emissions of HAPs. A certified control room operator must be on duty Minn. R. 7011.7410 at the site at all times the source is in operation. Control room operators must be trained under the requirements of, and certified (continued) under, the ASME Standard Number QHO -1 -1994 and QHO -1a -1996 Addenda (40 CFR 63.1206(c)(6)(iii), (v) & (vi)); (40 CFR 63.14(e)); or be trained and certified under a site - specific, source- Minn. R. 7011.7410 developed and implemented program that meets the requirements of 40 CFR 63.1206(c)(6)(v) -(vi); or be trained and certified under a State program. Control room operator requirements under the ASME program are as follows: - Control room operators must, prior to the compliance date, achieve provisional (continued) certification, and must submit an application to ASME and be scheduled for the (40 CFR 63.1206(c)(6)(iii)); full certification exam. Control room operators must achieve full certification Minn. R. 7011.7410 within one year of the compliance date; - New operators must, before assuming their duties, achieve provisional certification, and must submit an application to ASME, and be scheduled for the full certification exam. These operators must achieve full certification within one year of assuming their duties. Record the operator training and certification program in the operating record. 40 CFR 63.1206(c)(6)(vii); Minn. R. 7011.7410 Prepare and at all times operate according to an O &M Plan that describes in detail 40 CFR 63.1206(c)(7); procedures for operation, inspection, maintenance, and corrective measures for all Minn. R. 7011.7410 components of the combustor, including associated pollution control equipment, that could affect emissions of regulated HAPs. The plan must prescribe how the combustor will be operated and maintained in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels achieved during the CPT. Record the plan in the operating record. This plan ensures compliance with the O &M requirements of 40 CFR 63.6(e) and minimizes emissions of pollutants, automatic waste feed cutoffs, and malfunctions. PERFORMANCE TESTING hdr Performance Test: due 365 days after Permit Issuance to measure Fluoride and Minn. R. 7017.2020, subp. 1 Hydrogen Fluoride emissions, to verify emission factors. Performance Test: due 365 days after Permit Issuance to measure opacity. Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar 60 months starting 11/0112006 Minn. R. 7017.2020, subp. 1 to measure NOx and S02 emissions, to verify emission factors. The provisions of 40 CFR 63.7 apply, except as provided by 40 CFR 63.1207. 40 CFR 63.1207(a); Minn. R. 7011.7410 Conduct Comprehensive Performance Tests (CPTs) to demonstrate compliance 40 CFR 63.1207(b)(1); with the emission standards, establish limits for the operating parameters provided 40 CFR 63.1207(c)(3); by 40 CFR 63.1209, and demonstrate compliance with the performance 40 CFR 63.1207(d)(1) &(4); specifications for continuous monitoring systems. Minn. R. 7011.7410 The Permittee must commence testing no later than 61 months after the date of commencing the previous CPT. The initial CPT to demonstrate compliance with the replacement standards was conducted October 14 -16, 2009. The Permittee must submit to the Administrator a notification of the intention to 40 CFR 63.1207(e)(1)(i); conduct a CPT and CMS performance evaluation and a site - specific test plan and Minn. R. 7011.7410 CMS performance evaluation test plan at least one year before the performance test and performance evaluation are scheduled to begin. - The Administrator will notify the Permittee of approval or intent to deny approval of the site - specific test plan and CMS performance evaluation test plan within 9 months after receipt of the original plan. - Submit to the Administrator a notification of the intention to conduct the CPT at least 60 calendar days before the test is scheduled to begin. TABLE A: LIMITS AND OTHER REQUIREMENTS A -29 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Conduct confirmatory performance tests to: 40 CFR 63.1207(b)(2) &(d)(2); 1. Demonstrate compliance with the dioxin /furan emission standard when the Minn. R. 7011.7410 source operates under normal operating conditions; and 2. Conduct a performance evaluation of CMSs required for compliance assurance with the dioxin /furan emission standard under 40 CFR 63.1209(k). The Permittee must commence confirmatory performance testing no later than 31 months after the date of commencing the previous CPT used to show compliance with 40 CFR 63.1219. To ensure that the confirmatory test is conducted approximately midway between CPTs, the Administrator will not approve a test plan that schedules testing within 18 months of commencing the previous CPT. The Permittee must submit to the Administrator a notification of intention to 40 CFR 63.1207(e)(1)(11); conduct a confirmatory performance test and CMS performance evaluation and Minn. R. 7011.7410 a site - specific test plan and CMS performance evaluation test plan at least 60 calendar days before the performance test is scheduled to begin. The Administrator will notify the Permittee of approval or intent to deny approval of the site - specific test plan and CMS performance evaluation test plan within 30 calendar days after receipt of the original test plans. The Permittee must complete performance testing within 60 days after the date of 40 CFR 63.1207(d)(3); commencement, unless the Administrator determines that a time extension is Minn. R. 7011.7410 warranted based on the Permittee's documentation in writing of factors beyond the Permittee's control that prevents the Permittee from meeting the 60 -day deadline. The site - specific test plan and CMS performance evaluation test plan shall be made 40 CFR 63.1207(e)(2); available to the public for review no later than 60 calendar days before initiation of Minn. R. 7011.7410 the test. The test plans must be accessible to the public for 60 calendar days, beginning on the date of the public notice. The location must be unrestricted and provide access to the public during reasonable hours and provide a means for the public to obtain copies. The notification must include the following information: - The name and telephone number of the contact person; - The name and telephone number of the agency's contact person; - The location where the test plans and any necessary supporting documentation can be reviewed and copied; - The time period for which the test plans will be available for public review; and - An expected time period for commencement and completion of the performance test and CMS performance evaluation test. Petitions for time extension if Administrator fails to approve or deny test plans: 40 CFR 63.1207(e)(3); The Permittee may petition the Administrator under 40 CFR 63.7(h) to obtain a Minn. R. 7011.7410 "waiver" of any performance test; comprehensive or confirmatory test. The "waiver" would be an extension of time to conduct the performance test at a later date. Qualifications for the waiver: (continued) - The Permittee may not petition the Administrator for a waiver under this section (40 CFR 63.1207(e)(3)(i)); if the Administrator has issued a notification of intent todeny the test plan(s); Minn. R. 7011.7410 - The Permittee must submit a site - specific emissions testing plan and a CMS performance evaluation test plan at least one year before a CPT is scheduled to begin, or at least 60 days before a confirmatory performance test is scheduled to begin. The test plans must include all required documentation, including the substantive content requirements of 40 CFR 63.1207(f) and 40 CFR 63.8(e); and - The Permittee must make a good faith effort to accommodate the Administrator's comments on the test plans. Procedures for obtaining a waiver and duration of the waiver: (continued) - Submit to the Administrator a waiver petition or request to renew the petition (40 CFR 63.1207(e)(3)(ii)); under 40 CFR 63.7(h) separately for each source at least 60 days prior to the Minn. R. 7011.7410 scheduled date of the performance test. The Administrator will approve or deny the petition within 30 days of receipt and notify you promptly of the decision. - The Administrator will not approve an individual waiver petition for a duration exceeding 6 months. The Administrator will include a sunset provision in the waiver ending the waiver within 6 months. - The Permittee may submit a revised petition to renew the waiver under 40 CFR 63.7(h)(3)(iii) at least 60 days prior to the end date of the most recently approved waiver petition. The Administrator may approve a revised petition for a total waiver period up to 12 months. Content of the waiver: (continued) Provide documentation to enable the Administrator to determine that the source (40 CFR 63.1207(e)(3)(iii)); is meeting the relevant standards on a continuous basis as required by 40 CFR Minn. R. 7011.7410 63.7(h)(2). Include in the petition information justifying the request for a waiver, such as the technical or economic infeasibility, or the impracticality, of the affected source performing the required test, as required by 40 CFR 63.7(h)(3)(iii). TABLE A: LIMITS AND OTHER REQUIREMENTS A -30 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Public Notice: Notify the public (e.g., a notice to the public mailing list) of the (continued) petition to waive a performance test at the same time the petition is submitted to (40 CFR 63.1207(e)(3)(iv)); the Administrator. The notification must include all of the following information: Minn. R. 7011.7410 - The name and telephone number of the contact person; - The name and telephone number of the agency's contact person; - The date the site - specific performance test plan and CMS performance evaluation test plans were submitted; and - The length of time requested for the waiver. Content of Performance Test Plans: The provisions of 40 CFR 63.7(c)(2)(i)- (iii) &(v) 40 CFR 63.1207(f); regarding the content of the test plan apply. In addition, include the information Minn. R. 7011.7410 provided in 40 CFR 63.1207(f)(1) in the CPT plan, and the information provided in 40 CFR 63.1207(f)(2) in the confirmatory test plan. Operating Conditions During Testing hdr The Permittee must comply with the provisions of 40 CFR 63.7(e). Conducting 40 CFR 63.1207(g); performance testing under operating conditions representative of the extreme Minn. R. 7011.7410 range of normal conditions is consistent with the requirement of 40 CFR 63.7(e)(1) to conduct performance testing under representative operating conditions. Comprehensive performance testing - Operations during testing: 40 CFR 63.1207(g)(1)(i); For the following parameters, the Permittee must operate the combustor during Minn. R. 7011.7410 the performance test under normal conditions (or conditions that will result in higher than normal emissions): Chlorine feedrate. The Permittee must feed normal (or higher) levels of chlorine during the dioxin /furan performance test; - Ash feedrate. The Permittee must conduct the semivolatile metal and low volatile metal performance tests when feeding normal (or higher) levels of ash; and - Cleaning cycle of the particulate matter control device. The Permittee must conduct the PM, semivolatile metal, and low volatile metal performance tests when the particulate matter control device undergoes its normal (or more frequent) cleaning cycle. Modes of operation. The Permittee must establish limits for the applicable 40 CFR 63.1207(g)(1)(ii); operating parameters specified in 40 CFR 63.1209 based on operations during the Minn. R. 7011.7410 comprehensive performance test. The Permittee may conduct testing under two or more operating modes to provide operating flexibility. Steady -state conditions. Prior to obtaining performance test data, the Permittee 40 CFR 63.1207(g)(1)(iii); must operate under performance test conditions until steady -state operations are Minn. R. 7011.7410 reached with respect to emissions of pollutants to be measured during the performance test and operating parameters under 40 CFR 63.1209 for which the Permittee must establish limits. During system conditioning, the Permittee must ensure that each operating parameter for which the Permittee must establish a limit is held at the level planned for the performance test. Include documentation in the performance test plan justifying the duration of system conditioning. Confirmatory performance testing - Operations during testing: 40 CFR 63.1207(g)(2); The Permittee must conduct confirmatory performance testing for dioxin /furan Minn. R. 7011.7410 under normal operating conditions for the following parameters: Carbon monoxide (or hydrocarbon) CEMS emissions levels must be within the range of the average value to the maximum value allowed; - Each operating limit (in 40 CFR 63.1209) established to maintain compliance with the dioxin /furan emission standard must be held within the range of the average value over the previous 12 months and the maximum or minimum, as appropriate, that is allowed; The average value is defined as the sum of the rolling average values recorded (continued) (each minute) over the previous 12 months, divided by the number of rolling averages recorded during that time. The average value must not include calibration data, startup data, shutdown data, malfunction data, and data obtained when not burning hazardous waste; The Permittee must feed chlorine at normal feedrates or greater; and - The Administrator may approve an alternative range to that required by 40 CFR 40 CFR 63.1207(g)(2)(v); 63.1207(g)(2) if the Permittee documents in the confirmatory performance test Minn. R. 7011.7410 plan that it may be problematic to maintain the required range during the test. In addition, when making the finding of compliance, the Administrator may consider test conditions outside of the range specified in the test plan based on a finding that the Permittee could not reasonably maintain the range specified in the test plan and considering factors including whether the time duration and level of the parameter when operations were out of the specified range were such that operations during the confirmatory test are determined to be reasonably representative of normal operations. In addition, the Administrator will consider the proximity of the emission test results to the standard. TABLE A: LIMITS AND OTHER REQUIREMENTS A -31 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Operating Conditions During Subsequent Testing: 40 CFR 63.1207(h); Current operating parameter limits established under 40 CFR 63.1209 are waived Minn. R. 7011.7410 during subsequent comprehensive performance testing. Current operating parameter limits are also waived during pretesting prior to comprehensive performance testing for an aggregate time not to exceed 720 hours of operation (renewable at the discretion of the Administrator) under an approved test plan or if the source records the results of the pretesting. Pretesting means: - Operations when stack emissions testing for dioxin /furan, mercury, semivolatile metals, low volatile metals, particulate matter, or hydrochloric acid /chlorine gas is being performed; and - Operations to reach steady -state operating conditions prior to stack emissions testing under 40 CFR 63.1207(g)(1)(iii). Time Extension for Subsequent Performance Tests: 40 CFR 63.1207(i); The Permittee may request up to a one -year time extension for conducting a Minn. R. 7011.7410 comprehensive or confirmatory performance test to consolodate performance testing with other state or federally required emissions testing; or for other reasons deemed acceptable by the Administrator. If the Administrator grants a time extension for a comprehensive performance test, the deadlines for commencing the next comprehensive and confirmatory tests are based on the date that the subject comprehensive performance test commences. The request shall include the contents specified in 40 CFR 63.1207(i)(1) -(6). Notification of Compliance hdr Comprehensive Performance Test: Within 90 days of completion of a CPT, 40 CFR 63.12070)(1); postmark a NOC documenting compliance with the emission standards and CMS Minn. R. 7011.7410 requirements, and identifying operating parameter limits under 40 CFR 63.1209, except as provided by 40 CFR 63.12070)(4) (time extension). Upon postmark of the NOC, the Permittee must comply with all operating requirements specified in the NOC in lieu of the limits specified in the DOC required under 40 CFR 63.1211(c). Confirmatory Performance Test: Within 90 days of completion of a confirmatory 40 CFR 63.12070)(2); performance test, postmark a NOC documenting compliance or noncompliance Minn. R. 7011.7410 with the applicable dioxin /furan emission standard, except as provided by 40 CFR 63.12070)(4) (time extension). See 40 CFR 63.7(g) and 63.9(h) for additional requirements pertaining to the NOC 40 CFR 63.12070)(3); (e.g., the Permittee must include results of performance tests in the NOC). Minn. R. 7011.7410 Time extension. The Permittee may submit a written request to the Administrator 40 CFR 63.12070)(4); for a time extension documenting that, for reasons beyond the Permittee's control, Minn. R. 7011.7410 the Permittee may not be able to meet the 90 -day deadline for submitting the NOC after completion of testing. The Administrator will determine whether a time extension is warranted. Failure to Submit a Timely Notification of Compliance: 40 CFR 63.1207(k); If the Permittee fails to postmark a NOC by the specified date, the Permittee must Minn. R. 7011.7410 cease hazardous waste burning immediately. The Permittee must submit to the Administrator a NOC subsequent to a new CPT before resuming hazardous waste burning. Prior to submitting the revised NOC, the Permittee may burn hazardous waste only for the purpose of pretesting or comprehensive performance testing and only for a maximum of 720 hours (renewable at the discretion of the Administrator). Failure of Performance Test hdr Comprehensive performance test. If the Permittee determines (based on CEM 40 CFR 63.1207(I)(1)(i); recordings, results of analyses of stack samples, or results of CMS performance Minn. R. 7011.7410 evaluations) that the Permittee has exceeded any emission standard during a CPT for a mode of operation, the Permittee must cease hazardous waste burning immediately under that mode of operation. The Permittee must make this determination within 90 days following completion of the performance test. If the Permittee has failed to demonstrate compliance with the emission standards 40 CFR 63.1207(I)(1)(ii); for any mode of operation, the Permittee must conduct a CPT under revised Minn. R. 7011.7410 operating conditions following the requirements for performance testing of this section, and the Permittee must submit to the Administrator a NOC subsequent to the new CPT. Prior to submitting the revised NOC, the Permittee may burn hazardous waste only for the purpose of pretesting or comprehensive performance testing under revised operating conditions, and only for a maximum of 720 hours (renewable at the discretion of the Administrator). TABLE A: LIMITS AND OTHER REQUIREMENTS A -32 03106/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Confirmatory performance test. If the dioxin /furan emission standard is exceeded 40 CFR 63.1207(1)(2); during a confirmatory performance test, cease burning hazardous waste Minn. R. 7011.7410 immediately. Make this determination within 90 days of completion of the test. To bum hazardous waste in the future: 1. Submit to the Administrator a test plan to conduct a CPT to identify revised limits on the applicable dioxin /furan operating parameters specified in 40 CFR 63.1209(k); 2. Submit to the Administrator a NOC with the dioxin /furan emission standard under 40 CFR 63.12070), (k) & (1). Include in the Notification the revised limits on the applicable dioxin /furan operating parameters specified in 40 CFR 63.1209(k); and 3. Until the NOC is submitted, the Permittee must not burn hazardous waste except for purposes of pretesting or confirmatory performance testing, and for a maximum of 720 hours, except as provided by 40 CFR 63.1207(1)(3) below. The Permittee may petition the Administrator to obtain written approval to burn 40 CFR 63.1207(1)(3); hazardous waste in the interim prior to submitting a NOC for purposes other than Minn. R. 7011.7410 testing or pretesting. The Permittee must specify operating requirements, including limits on operating parameters, that are determined to ensure compliance with the emission standards of subp. EEE based on available information including data fron the failed performance test. The Administrator will review, modify as necessary, and approve if warranted the interim operating requirements. An approval of interim operating requirements will include a schedule for submitting a NOC. Waiver of Performance Test hdr The Permittee is not required to conduct performance tests to document 40 CFR 63.1207(m); compliance with the mercury, semivolatile metals, low volatile metals or hydrogen Minn. R. 7011.7410 chloride /chlorine gas emission standards under the conditions specified below. The waiver provisions apply in addition to the provisions of 40 CFR 63.7(h). The Permittee must state in the site - specific test plan submitted for review and 40 CFR 63.1207(m)(5); approval under 40 CFR 63.1207(e) that the Permittee intends to comply with the Minn. R. 7011.7410 waiver provisions of 40 CFR 63.1207(m). The Permittee must include in the test plan documentation that any surrogate that is proposed for gas flowrate adequately correlates with the gas flowrate. The Permittee is deemed to be in compliance with an emission standard if the 40 CFR 63.1207(m)(1)(i); twelve -hour rolling average MTEC does not exceed the emission standard, Minn. R. 7011.7410 determined as specified below: - Determine the feedrate of mercury, semivolatile metals, low volatile metals, or total chlorine and chloride from all feedstreams; - Determine the stack gas flowrate; and - Calculate a MTEC for each standard assuming all mercury, semivolatile metals, low volatile metals, or total chlorine (organic and inorganic) from all feedstreams is emitted. To document compliance with the waiver provisions of 40 CFR 63.1207(m): 40 CFR 63.1207(m)(1)(ii)- (iii); Monitor and record the feedrate of mercury, semivolatile metals, low volatile Minn. R. 7011.7410 metals, and total chlorine and chloride from all feedstreams according to 40 CFR 63.1209(c); - Monitor with a CMS and record in the operating record the gas flowrate (either directly or by monitoring a surrogate parameter correlated to gas flowrate); Identify in the NOC a minimum gas flowrate limit and a maximum feedrate limit of mercury, semivolatile metals, low volatile metals, and /or total chlorine and chloride from all feedstreams that ensures the calculated MTEC is below the applicable emission standard; and Interlock the minimum gas flowrate limit and maximum feedrate limit to the AWFCO system to stop hazardous waste burning when the gas flowrate or mercury, semivolatile metals, low volatile metals, and /or total chlorine and chloride feedrate exceeds the limits specified above. When determining the feedrate of mercury, semivolatile metals, low volatile metals, 40 CFR 63.1207(m)(3); or total chlorine and chloride for purposes of this provision, assume that the analyte Minn. R. 7011.7410 is present at the full detection limit when the feedstream analysis determines that the analyte is not detected in the feedstream. TEST METHODS hdr The Permittee shall use the test methods listed in 40 CFR 63.1208(b) to determine 40 CFR 63.1208(b); compliance with the emissions of subpart EEE. Minn. R. 7011.7410 MONITORING REQUIREMENTS hdr The provisions of 40 CFR 63.8(g) apply for reduction of monitoring data. 40 CFR 63.1209(h); Minn. R. 7011.7410 Continuous Emissions Monitoring Systems hdr TABLE A: LIMITS AND OTHER REQUIREMENTS A -33 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Performance Specifications (PS). The Permittee must install, calibrate, maintain, 40 CFR 63.1209(a)(2); and continuously operate the CEMS in compliance with the quality assurance Minn. R. 7011.7410 procedures provided in the appendix to Subpart EEE and PS -1, PS -413, and PS -8A in 40 CFR Part 60, appendix B. CO readings exceeding the span. If a CO CEMS detects a response that results 40 CFR 63.1209(a)(3); in a one - minute average at or above the 3,000 ppmv span level required by PS -413, Minn. R. 7011.7410 the one - minute average must be recorded as 10,000 ppmv. The one - minute 10,000 ppmv value must be used for calculating the hourly rolling average CO level. Calculation of rolling averages upon intermittent operations: Ignore periods of time 40 CFR 63.1209(a)(6)(ii); when one - minute values are not available for calculating the hourly rolling average. Minn. R. 7011.7410 When one - minute values become available again, the first one - minute value is added to the previous 59 values to calculate the hourly rolling average. Calculation of rolling averages when the hazardous waste feed is cutoff: 40 CFR 63.1209(a)(6)(iii); Continue monitoring carbon monoxide when the hazardous waste feed is cutoff Minn. R. 7011.7410 if the source is operating. Hazardous waste feed must not be resumed if the emission levels exceed the standard. Operating Parameter Limits (OPLs) for hydrocarbons: Demonstrate that 40 CFR 63.1209(a)(7); hydrocarbon emissions during the CPT do not exceed the hydrocarbon emissions Minn. R. 7011.7410 standard. In addition, the OPLs established for DIRE required under 40 CFR 63.12090) also ensure that compliance is maintained with the hydrocarbon emission standard. If the Permittee does not conduct the hydrocarbon demonstration and DIRE tests concurrently, establish separate OPLs under 40 CFR 63.12090) based on each test and the more restrictive of the OPLs applies. Other Continuous Monitoring Systems (CMS) hdr Use CMS (e.g., thermocouples, pressure transducers, flow meters) to document 40 CFR 63.1209(b)(1); compliance with the applicable operating parameter limits under subpart EEE. Minn. R. 7011.7410 Install and operate CMS other than CEMS in conformance with 40 CFR 63.8(c)(3) 40 CFR 63.1209(b)(2); that requires, at a minimum, compliance with the manufacturer's written Minn. R. 7011.7410 specifications or recommendations for installation, operation, and calibration of the system, except: - The calibration of thermocouples must be verified at a frequency and in a manner consistent with manufacturer specifications, but no less frequent than once per year. Operate and maintain optical pyrometers in accordance with manufacturer specifications, and calibrate optical pyrometers in accordance with the frequency and procedures recommended by the manufacturer, but no less frequent than once per year, unless otherwise approved by the Administrator. CMS must sample the regulated parameter without interruption, and evaluate the 40 CFR 63.1209(b)(3); detector response at least once each 15 seconds, and compute and record the Minn. R. 7011.7410 average values at least every 60 seconds. The span of the non -CEMS CMS detector must not be exceeded. Interlock the 40 CFR 63.1209(b)(4); span limits into the AWFCO system required by 40 CFR 63.1206(c)(3). Minn. R. 7011.7410 Calculation of rolling averages upon intermittent operations: Ignore periods 40 CFR 63.1209(b)(5)(0); of time when one - minute values are not available for calculating rolling averages. Minn. R. 7011.7410 When one - minute values become available again, the first one - minute value is added to the previous one - minute values to calculate rolling averages. Calculation of rolling averages when the hazardous waste feed is cutoff: 40 CFR 63.1209(b)(5)(iii); Continue monitoring operating parameter limits with a CMS when the hazardous Minn. R. 7011.7410 waste feed is cutoff if the source is operating. Hazardous waste feed must not be resumed if an operating parameter exceeds its limit. Analysis of Feedstreams hdr Prior to feeding the material, obtain an analysis of each feedstream that is sufficient 40 CFR 63.1209(c)(1); to document compliance with the applicable feedrate limits in 40 CFR 63.1209. Minn. R. 7011.7410 Develop and implement a feedstream analysis plan and record it in the operating 40 CFR 63.1209(c)(2); record. The plan must specify at a minimum: Minn. R. 7011.7410 - The parameters for which each feedstream will be analyzed to ensure compliance with operating parameter limits; - If the analysis will be obtained by performing sampling and analysis or by other methods; - How the analysis will be used to document compliance with applicable feedrate limits; - The test methods to be used to obtain the analyses; - The sampling method used to obtain a representative sample of each feedstream to be analyzed using sampling methods described in 40 CFR 266, appendix IX, or an equivalent method; and - The frequency with which the initial analysis of the feedstream will be reviewed or repeated to ensure that the analysis is accurate and up to date. TABLE A: LIMITS AND OTHER REQUIREMENTS A -34 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Review and approval of analysis plan. Submit the feedstream analysis plan 40 CFR 63.1209(c)(3); to the Administrator for review and approval, if requested. Minn. R. 7011.7410 Compliance with feedrate limits. To comply with the applicable feedrate limits 40 CFR 63.1209(c)(4); of 40 CFR 63.1209, monitor and record feedrates as follows: Minn. R. 7011.7410 - Determine and record the value of the parameter for each feedstream by sampling and analysis or other method; - Determine and record the mass or volume flowrate of each feedstream by a CMS. If the flowrate of a feedstream is determined by volume, then determine and record the density of the feedstream by sampling and analysis (unless the constituent concentration is reported in units of weight per unit volume; and - Calculate and record the mass feedrate of the parameter per unit time. Waiver of monitoring of constituents in certain feedstreams. Monitoring levels of 40 CFR 63.1209(c)(5); metals or chlorine is not required in the following feedstreams to document Minn. R. 7011.7410 compliance with the feedrate limits under this section provided that the CPT plan documents the expected levels of the constituent in the feedstream and accounts for those assumed feedrate levels in documenting compliance with feedrate limits: - natural gas, - process air, and - feedstreams from vapor recovery systems. Performance Evaluations: The requirements of 40 CFR 63.8(d) (Quality control 40 CFR 63.1209(d); program) and (e) (Performance evaluation of CMSs) apply, except that performance Minn. R. 7011.7410 evaluations of components of the CMS must be conducted under the frequency and procedures applicable to performance tests as provided by 40 CFR 63.1207. Comply with the quality assurance procedures for CEMS prescribed in the appendix to subpart EEE. Conduct of Monitoring. The provisions of 40 CFR 63.8(b) apply. 40 CFR 63.1209(e); Minn. R. 7011.7410 Operation and Maintenance of CMS: Provisions of 40 CFR 63.8(c) apply except: 40 CFR 63.1209(f); - 40 CFR 63.8(c)(3). The requirements of 40 CFR 63.1211(c), that requires CMSs Minn. R. 7011.7410 to be installed, calibrated, and operational on the compliance date, shall be complied with instead of 40 CFR 63.8(c)(3); - 40 CFR 63.8(c)(4)(11). The PSs for CO, hydrocarbon, and 02 CEMSs in Part 60, subpart B that requires detectors to measure the sample concentration at least once every 15 seconds for calculating an average emission rate once every 60 seconds shall be complied with instead of 40 CFR 63.8(c)(4)(ii). Alternative Monitoring Requirements other than CEMS hdr An application may be submitted to the Administrator under 40 CFR 63.1209(g) 40 CFR 63.1209(g)(1); for approval of alternative monitoring requirements to document compliance with Minn. R. 7011.7410 the emission standards of subpart EEE, by following the requirements listed in 40 CFR 63.1209(g)(1). The Administrator may determine on a case -by -case basis at any time that the 40 CFR 63.1209(g)(2); Permittee needs to limit additional or alternative operating parameters or that Minn. R. 7011.7410 alternative approaches to establish limits on operating parameters may be necessary to document compliance with the emission standards of subpart EEE. Reduction of Monitoring Data. The provisions of 40 CFR 63.8(g) apply. 40 CFR 63.1209(h); Minn. R. 7011.7410 When an Operating Parameter is Applicable to Multiple Standards. 40 CFR 63.1209(i); 40 CFR 63.12090) -(p) requires limits on operating parameters top be established Minn. R. 7011.7410 based on comprehensive performance testing to ensure compliance is maintained with the emission standards of subpart EEE. For several parameters, a limit must be established for the parameter to ensure compliance with more than one emission standard. If the performance tests for such standards are not performed simultaneously, the most stringent limit for a parameter derived from independent performance tests applies. NOTIFICATION, REPORTING, AND RECORDKEEPING REQUIREMENTS hdr The dumpstack shall not be used except in emergencies. Minn. R. 7007.0800, subp. 2 For each instance of dumpstack use, the Permittee shall keep a record of the date Minn. R. 7007.0800, subp. 5 of use, the length of time the dumpstack was used, the operating conditions of the incinerator, and the reason for each dumpstack use. TABLE A: LIMITS AND OTHER REQUIREMENTS A -35 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 The NOC status requirements of 40 CFR 63.9(h) and 63.12070) apply, except that: 40 CFR 63.1210(d); The notification is a Notification of Compliance, rather than compliance status; Minn. R. 7011.7410 The notification is required for the initial CPT and each subsequent CPT and confirmatory performance test; and The notification must be postmarked before the close of business on the 90th day following completion of relevant compliance demonstration activity specified in this subpart rather than the 60th day as required by 40 CFR 63.9(h)(2)(11). Upon postmark of the NOC, the operating parameter limits identified in the NOC, as applicable, shall be complied with, the limits identified in the DOC or a previous NOC are no longer applicable. Include the DOC prepared under 40 CFR 63.1211(c) in the operating record. The 40 CFR 63.1211(c); DOC must identify the applicable emission standards under subpart EEE and the Minn. R. 7011.7410 OPI-s that will ensure compliance with those standards. The limits identifed in the DOC are no longer applicable, they have been superceded by the NOC. TABLE A: LIMITS AND OTHER REQUIREMENTS A -36 03106/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: EU 011 Waste Processing via Komar Shredder Associated Items: SV 026 Komar Relief Panels Dump Stack What to do Why to do it The dumpstack shall not be used except in emergencies. Minn. R. 7007.0800, subp. 2 For each instance of dumpstack use, the Permittee shall keep a record of the date Minn. R. 7007.0800, subp. 5 of use, the length of time the dumpstack was used, the operating conditions, and the reason for each dumpstack use. TABLE A: LIMITS AND OTHER REQUIREMENTS A -37 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: EU 014 Emergency Generator Associated Items: SV 028 Emergency Generator Stack What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures Minn. R. 7011.2300, subp. 1 have been attained. Sulfur Dioxide: less than or equal to 0.5 Ibs /million Btu heat input Minn. R. 7011.2300, subp. 2 EU 014 is not required to meet the requirements of 40 CFR, Subpart ZZZZ and 40 CFR 63.6590(b)(1)(i) Subpart A. Minn. R. 7011.8150 The initial notification was submitted on November 3, 2005. TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: CE 004 Subcooling Vessel Associated Items: ELI 008 Replacement Rotating Kiln MR 001 Subcooler H2O pH A -38 03/06/12 What to do Why to do it Liquid Flow Rate: greater than or equal to 3250 gallons /minute using 1 -Hour Rolling 40 CFR 63.1209(m)(1)(i)(C), (n)(5), (o)(3)(v) Average for recirculation water flow, unless a new minimum flow rate is required to be set pursuant to Minn. R. 7017.2025, subp. 3. Water pressure: greater than or equal to 19.40 psi (gauge) using 1 -Hour Rolling 40 CFR 63.1209(1)(2), (o)(3)(i) Average minimum scrubber liquid feed pressure, unless a new minimum feed pressure is required to be set pursuant to Minn. R. 7017.2025, subp. 3. Water flow rate: greater than or equal to 194.0 gallons /minute using 1 -Hour Rolling 40 CFR 63.1209(m)(1)(1)(B), (n)(3), (g)(1) Average minimum combined blow down rate for the Subcooling Vessel and the per approved alternative monitoring application Venturi Quench (CE 010), unless a new minimum combined blow down rate is required to be set pursuant to Minn. R. 7017.2025, subp. 3. See also CE 010. pH: greater than or equal to 1.5 pH using 1 -Hour Rolling Average of the Scrubber 40 CFR 63.1209(o)(3)(iv) Liquid, unless a new minimum pH is required to be set pursuant to Minn. R. 7017.2025, subp. 3. TABLE A: LIMITS AND OTHER REQUIREMENTS A -39 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: CE 005 M1 Module Associated Items: ELI 008 Replacement Rotating Kiln What to do Why to do it Pressure Drop: less than or equal to 16.1 inches of water column using 1 -Hour 40 CFR 63.1209(m)(1)(i)(A), (o)(3)(i) Rolling Average , unless a new maximum pressure drop is required to be set pursuant to Minn. R. 7017.2025, subp. 3. Water flow rate: greater than or equal to 128.0 gallons /minute using 1 -Hour Rolling 40 CFR 63.1209(m)(1)(i)(B), (n)(3), (g)(1) Average minimum make -up rate, unless a new minimum water make -up rate is per approved alternative monitoring application required to be set pursuant to Minn. R. 7017.2025, subp. 3. (As approved alternative to comply with minimum blow down rate limit). Liquid to Gas (L /G) Ratio: greater than or equal to 39.0 gallons per 1000 standard 40 CFR 63.1209(m)(1)(i)(C), (n)(3), (o)(3)(v) cubic feet using a 1 -Hour Rolling Average, , unless a new minimum UG ratio is required to be set pursuant to Minn. R. 7017.2025, subp. 3. TABLE A: LIMITS AND OTHER REQUIREMENTS A -40 03/06/12 Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: CE 009 Fabric Filter -Low Temperature, i.e., T <180 Degrees F Associated Items: EU 013 Lime Silo What to do Why to do it Visible Emissions: The Permittee shall check the fabric filter for any visible Minn. R. 7007.0800, subps. 4 & 5 emissions once each time the unit is operating. Recordkeeping of Visible Emissions: The Permittee shall record the time and date Minn. R. 7007.0800, subps. 4 & 5 of each visible emission inspection and whether or not any visible emissions were observed. The Permittee shall operate and maintain the fabric filter in accordance with the Minn. R. 7007.0800, subp. 14 O &M Plan. The Permittee shall keep copies of the O &M Plan available onsite for use by staff and MPCA staff. Corrective Actions: The Permittee shall take corrective action as soon as possible Minn. R. 7007.0800, subps. 4, 5 & 14 if any of the following occur: Visible emissions are observed; or The fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and /or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O &M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for the filter. TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: CE 010 Venturi Quench Associated Items: EU 008 Replacement Rotating Kiln A-41 03/06112 What to do Why to do it Temperature: less than or equal to 182 degrees F using 1 -Hour Rolling Average for Minn. R. 7007.0800, subp. 14 the quench outlet flue gas temperature. Water flow rate: greater than or equal to 194.0 gallons /minute using 1 -Hour Rolling 40 CFR 63.1209(m)(1)(i)(B), (n)(3), (g)(1) Average minimum combined blow down rate for the Subcooling Vessel (CE 004) per approved alternative monitoring application and the Venturi Quench, unless a new minimum combined blow down rate is required to be set pursuant to Minn. R. 7017.2025, subp. 3. See also CE 004. TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Subject Item: CE 011 Electrostatic Precipitator- High Efficiency Associated Items: EU 008 Replacement Rotating Kiln A-42 03/06/12 What to do Why to do it Total Power Input: greater than or equal to 9.52 kilowatts using 1 -Hour Rolling 40 CFR 63.1209(m)(1)(iv)(A -C) Average , unless a new minimum Total Power Input is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If the 1 -hour rolling average total power input drops below the minimum limit, this shall be reported as a deviation. Operate the control equipment any time the incinerator is operating except while Minn. R. 7007.0800, subp. 2 burning only natural gas. The WESP shall be operated with at least the minimum specific collection area Minn. R. 7007.0800, subp. 14 (SCA) in service determined during the most recent particulate matter performance test showing compliance. The WESP cleaning cycle total (min /hour) using 8 -hour block average shall not Minn. R. 7007.0800, subp. 14 exceed the average duration (min /hour) demonstrated the most recent Comprehensive Performance Test. For the purposes of trouble- shooting only, the facility may increase the total cleaning cycle duration by up to 10% while remaining in compliance with the minimum kW requirement for up to: 10 hrs /yr while burning hazardous waste; and 24 hrs /yr while burning #2 Fuel Oil only MONITORING AND RECORDKEEPING hdr Monitor and record the minimum SCA in service each day of operation. Minn. R. 7007.0800, subps. 4 & 5 Calculate and record the 8 -hour block average WESP spray /cleaning time. Data Collection: The Permittee shall maintain a continuous hard copy readout or Title I Condition: To avoid classification as a major computer disk file of the total power input. The total power input shall be calculated source and modification under 40 CFR 52.21 and and recorded at least once every 15 minutes. The three -hour rolling total power Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 and input shall be calculated and recorded based on the 15- minute readings. 5 Daily Monitoring: The Permittee shall physically verify the operation of the Minn. R. 7007.0800, subps. 4 and 5 Continuous Parameter Monitoring System (CPMS) at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. Monitoring Equipment: The Permittee must install and maintain a CPMS for Minn. R. 7007.0800, subps. 4 and 5 monitoring the ESP total power input as required by this permit. The monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. Annual Inspections: At least once per calendar year, or more frequently if required Minn. R. 7007.0800, subps. 4, 5 and 14 by the manufacturer, the Permittee shall inspect the control equipment components. This includes, but is not limited to: components that are not subject to wear or plugging including structural components, housings, and hoods; and components that are subject to wear or plugging, including bearings, belts, hoses, fans, nozzles, orifices, and ducts. Maintain a written record of the inspection and any corrective actions taken resulting from the inspection. Annual Calibration: Calibrate the total power input monitor at least at least once Minn. R. 7007.0800, subps. 4, 5 and 14 each 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. Replacement is acceptable in lieu of calibration. Corrective Actions: The Permittee shall take corrective action as soon as possible if Minn. R. 7007.0800, subps. 4, 5 and 14 any of the following occur: Any recorded operating parameter is outside the required operating range; or The ESP or any of its components are found during an inspection to need repair. Corrective actions shall return operation to within the permitted range and /or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O &M Plan for the ESP. The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. Operation and Maintenance of ESP: The Permittee shall operate and maintain the Minn. R. 7007.0800, subp. 14 ESP in accordance with the O &M Plan. The Permittee shall keep copies of the O &M Plan available onsite for use by staff and review by MPCA staff. TABLE B: SUBMITTALS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604 B -1 03/06/12 Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send any application for a permit or permit amendment to: AQ Permit Document Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155 -4194 Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one -time only and recurrent submittal requirements. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460 Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155 -4194 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 B -2 03/06/12 What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit Testing Frequency Plan due 60 days after Performance Test for E0008 opacity. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12- month, 36- month, or 60 -month intervals, or as applicable, shall be required upon written approval of the MPCA. TABLE B: RECURRENT SUBMITTALS Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 - 002 B -3 03106/12 What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half -year starting 02/14/2005. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occured, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year Total Facility starting 02/14/2005 (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. APPENDIX A Table 1 to Subpart EEE of Part 63 - General Provisions Applicable to Subpart EEE Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025 -002 Reference Applies Explanation 63.1 -5 Yes 63.8(e) Yes 63.6 (a)-(e) Yes eval uation test plan f or - app roval at leas one year prior to the plan tes date a inst of § §63.8(e)(2) an (3)(iii) - - -- - - - - -- - - - - -- - - -- - 63.6(f) - -- Ye - Except t hat the performa tes requirements of Sec. 63.12 apply inste of §63.gq(2) - - -- 63.6( Yes Note: Section 63.9(b)(1)(ii) pertains to notification requirements for area sources that become a major source, and §63.9(b)(2)(v) 63.6(i) __ Yes - Section 63.1213 specifies that the compliance date may also be extended for inability to install necessary emission control -__ equipment by the com l�ian ce_date because of implementati of pollution prevention_or waste in controls. _. 63.60) Yes _ - - 63.7(a) Yes Except §63.1207(e)(3) allows you to petition the Administrator under §63.7(h) to provide an extension of time to conduct a 63.9(f) Yes Section 63.9(f) applies if you are allowed under §63.1209(a)(1)(v) to use visible determination of opacity for compliance in p erformance test. 63.7(b) Yes Except §63.1207(e) requires you to submit the site - specific test plan for approval at least one year before the comprehensive 63.9(h) Yes Except §63.12070) requiring you to submit the notification of compliance within 90 days of completing a performance test per test is sch to be gin. 63.7(c) Yes Except §63.1207(e) requires you to submit the site - specific test plan (including the quality assurance provisions under - - -- - §63.70) forapproval at least one year before the comprehensive performance test is scheduled to_begin. 63.7(d) Yes 63.7(e) Yes Except §63.1207 prescribes operations during performance testing and §63.1209 specifies operating limits that will be established _ during performance testing (such that_testing is likely to b r epresentative of the ext range of normal pe 63.7(f) Yes 63.7(g) Yes Except §63.12070) requiring that you submit the results of the performance test (and the notification of compliance) within 90 d ays of completing the test, unless the Administrator grants a time e applies instea o f §63.7(g)Q)._ _ - - 63.7(h) Yes Except §63.1207(c)(2) allows data in lieu of the initial comprehensive performance test, and §63.1207(m) provides a waiver of certain performance tests. You must submit requests for these waivers with the site - specific test plan. 63.8 a Y - -- -( ) -(b ) es ----- - - - - -- - ------ - - - - -- ------------------------ - - - - -- -- ----- - ------- - ------ -- ----- -- ------- 63.8(c) Yes Except: (1) §63.1211(c) that requires you to install, calibrate, and operate CMS by the compliance date applies instead of §63.8(c)(3); and (2) the performance specifications for CO, HC, and 02 CEMS in subpart B, of this chapter requiring that the detectors measure the sample concentration at least once every 15 seconds for calculating an average emission level once ._... - - - - -- -every 60 seconds amply instead of §63.8(c)(4)f11)_ --------- - - - - -- ------- - --- - - ------- - -- ------------- - - - - -- ------ ------- 6 3.8(d) Yes 63.8(e) Yes Except §63.1207(e) requiring you to submit the site - specific comprehensive performance test plan and the CMS performance eval uation test plan f or - app roval at leas one year prior to the plan tes date a inst of § §63.8(e)(2) an (3)(iii) - - -- - - - - -- - - - - -- - - -- - 6 ___Ye s___ _ _ _ _ _ _ __ - - -_ - -- - - -- -- - - ---- - - - _ _ - -- - - -- - - --------- 63.9(a)___ 63.9(a)___ - Yes - -- - -- - -- -- -- - - - - -- - - - - -- - - - - -- - 63.9(b) Yes Note: Section 63.9(b)(1)(ii) pertains to notification requirements for area sources that become a major source, and §63.9(b)(2)(v) requires a major source determination. Although area sources are subject to all provisions of this subpart (Subpart EEE), these sections nonetheless apply because the major source determination may affect the applicability of part 63 standards or title V hermit requirements to other sources (Le., other than a hazardous waste combustor) of HAPs at the facility _______- 63.9(c) -(d) Yes - - 63.9(e) Yes Except §63.1207(e) which requires you to submit the comprehensive performance test plan for approval one year prior to the p lanned perfor test date a pplies instead of §63.9(e). 63.9(f) Yes Section 63.9(f) applies if you are allowed under §63.1209(a)(1)(v) to use visible determination of opacity for compliance in lieu of a COMS. 6 Yes Except §63. )(2) pert to COMS does n appl __ _ _ _ 63.9(h) Yes Except §63.12070) requiring you to submit the notification of compliance within 90 days of completing a performance test unless the Administrator grants a time extension applies instead of §63.9(h)(2)(iii). Note: Even though area sources are subject to this subpart, the major source determination required by §63.9(h)(2)(i)(E) is applicable to hazardous waste combustors for the reasons discussed above. 63.9(i) (j) _Yes .. -- ------ - - - - -- 63.10 Yes Exc� re of perform ance te st results req uired under §63. 10(d)L2�ybe submi tted up to 90 d ays a fter com pletion of the test. 63.1 N - - -- - - - -- - -- - 63.12 -15 Yes APPENDIX B Table 2 to Subpart DD of Part 63 - General Provisions Applicable to Subpart DD Facility Name: 3M - Cottage Grove Corporate Incinerator Permit Number: 16300025-002 Reference Applic Explanation 9 6 3,1.(x)(1)-(31 s No - -- ---_ 63.1(a)(4) -Ye . No ............ Subp. DD (this table) specifies applicability of each paragraph in subp. A to 6 M determining j. (6(2j6.T 63 subp. DD. 63.l(a)_(5) -_(9)__ No No 14)_ Yes - -- ----- ------ ---------------- --------------- - -------- -------------- ------- - -------------------------- 611(b)(1) No - ------ Subp DD specifies its own applicability. 63.1(6)(2) Yes - 63.1(6)(3) No Yes ________., ------------------------------- 63.7(h)Qj-Q_j_ j ............................. - - - § .......... .... jbp. DDompLicid, specifi r y _req ____ m _tba t app1y­________ - -- ____ 63.1(c)C2) No Area sources are not subject to subp. DD. ..................... 63.1(c)S3) No -Yes 63 Yes No 63.1(c)(5) Yes Except that sources are not required to submit notifications overridden by this --------------- - --- -- - - ____ 63.8(b)(2) table. 63 1(d )-(c No - D - - that - i - clefi - 63.2 Yes w's D specifies f term is ned A ....... -------------------------------- 6 3 . 8 (q(1)' . (3) . and DD, it shall have the meaning given in ............... -- - -- Yes -- 6 3.4 (4yjik3 Yes No 63.4 a .......... NoR served. .. .. .. .......... . ... ... ............ .... S­­ .... . ...................... .............. .......... ....... ....... ...... . ........ . .. 63_4(a)15) Yes Yes 63A(b)-(c) Yes - ---------------- ----------- - ------------ -- ----------- ------ 63.5(a) Yes Except replace term "source" and "stationary source" in §63.5(a)(1) 63.8(f)(5)(ii) of subp_ A with "affected soijrcc ........... . .. ..... ........... . .. . ............ . . . ............. - ---------------- 03 5(b)(1) __ 63.;�(b)(2)_ No Reserved.__ 63.5(6)(3)-(6) Yes Except the cross-reference to §63.9(6) is changed to §63.9(b)(4)&(5). Subo. DD overrides Reference Applies Explanation 63-7(AQj-(3)_ - -Yes - - -- 63.7(b)-(c) No - - - ----- -------- ------ ------------- --- - ------------- 63.70 ___ _ ___ Yes 6 M determining j. (6(2j6.T 63 Yes 63.10(b)(3) 63.Z(e)(3j No Sop. DD specifies test methods and procedures. 63 7(e)_(1 Yes - - -------- ---- --------------- . ... ... . ..... .......... . .......... ... . .......... ................... ..... 63.7(1) No Subp. DD specifies applicable methods and 63.6(b)(4) No rovides alternatives. 63.6(6)(5) _ __ Yes ________., ------------------------------- 63.7(h)Qj-Q_j_ Yes Yes 63,T(h)(4) __ ____ No ------------ ---- - - - -- ----- - -- ------------ 63 . 7 (h)_ft..­-.--­- -Yes ---------- 63.8(a) No .. . .......... ... - - ------- ---- ------ - 6 No --------------- - --- -- - - ____ 63.8(b)(2) No Subp. DD specifies locations to conduct 63.6(f)(1) Yes .............................. 6M b fl)(3) _ - - - -- _ Yes ....... -------------------------------- 6 3 . 8 (q(1)' . (3) . Yes 63.8 1- _(8) m monitoring c c 63_8(d)-(e) .......... No ----------- ---------- ---------- ---------- 63.8(f)(I)-(3) Yes 63.8(f)(4)(i)-(ii) Yes . . .... ...... 631(f)(11(iii)_ No ... . . ........... .. - ----- . .... ...... . .... 63.8(f)15)0, _ __Yes 63.8(f)(5)(ii) No ---------- -- --- - ------- - ------- - -- ------------------- - - ------ - - ------------------------ Xt)6 --- ---- -- ---- ---- 63.5(c) Yes 15- - - - w) --------------- No Reserved. - I - ------ ---- --- ( ------- ------------------------------ - ---- ------ - 63.5(4)11) Yes 63 -.­-­­- 6) s Ye 4C ......... - - --- -------- ---------- --------- ----------- A I 419(-1 V­ . ( A 1­.--­­.-­------- Yes - --------- - 63_5(d)(3) Yes______ - - - ----- -------- ------ ------------- ....... 63.5(c) __ Yes 6 M determining j. (6(2j6.T 6.6(a) -------------- Y 63.10(b)(3) 63.6f ...... _ No e subj ect t S specifie s wo�ubp- p_aDspc dates for sources 63.6� f)(2)(iii)(A)- f - - -------- ---- --------------- . ... ... . ..... .......... . .......... ... . .......... ................... ..... 6.6(b)(3) .......... Yes ........... 63b_(Q(2)(ii HIT 63.6(b)(4) No May apply when standards are proposed under section 112(f) of the CAA. 63.6(6)(5) _ __ , _No_ §63,697 of subp_ DD includes notification regnirements. 63.6(b)(6)-(7) No Yes 63.6(c)(1) No §63.680 of subpart DD specifies the compliance date. 63 - (4) . - . N -- - - q1 6 (0(5) Yes .. . .......... ... jq(e) No Yes -6 ]1 is reserved. W. ... . ..................... . ....... ......... ...................... . ... Yes 63.6(1)______ - _ 63.6(f)(1) Yes 63.11-63.15___ ----------No ... _ _ _ _ ... . - Yes . ........................................ Yes Yes Yes No No 63.6(f)(2)(i) Yes 63. 1 O(b)(2)(xii)- - - - - --- - -- --- -- - -- --- --- - ---- --- -- -- --- - - -- -- - - --- - -- - - - - ---- -- --- --- -- ­ ( -- ------- ---------- 6 M determining j. (6(2j6.T '�e s specifies th use ofmonitoring data in compliance 63.10(b)(3) - - - with subp. DD. 63.6� f)(2)(iii)(A)- f Yes 63b_(Q(2)(ii HIT No 6 3. 10(4)( ?) 63.6(fl(3) Yes . . ............. . .... ... ........ -- - - - - -- 63.10(4)(3) ........... fil§(O Yes 63. 10(d)(4 63.6(h) subp- RI? does Rqnquwe opmy_ an jq(e) Yes -6 ]1 is reserved. W. ... . ..................... . ....... ......... ...................... . ... 6 3 - 10(f) 63.6(1)______ - _ Yes 63.11-63.15___ 63.7(a)(1) No SubD. DD snecifies reouired testing and compliance demonstration procedures.1 Yes - Yes . ... .. .... No - ----------- - ------ . . ....... Yes Yes No Yes No No Yes No Yes No Yes APPENDIX C Insignificant Activities and General Applicable Requirements Facility Name: 3M — Cottage Grove Corporate Incinerator Permit Number: 16300025 -002 This table lists the insignificant activities that are currently at the facility and their general applicable requirements. Minn. R. General 7007.1300, Rule Description of the Activity Applicable subp. Requirement 3(B)(2) Fuel burning equipment with a capacity less than 500,000 Btu/hr, but only if the Minn. R. 7011.0515 total of this equipment is less than 2,000,000 Btu/hr. Propane Radiant Heater —Bldg 181. Ca aci of 100,000 Btu /hr 3(J) Fugitive Emissions for roads and parking lots. Minn. R. 7011.0150 3(I)(2) Individual emission units at a stationary source, each of which have a potential to Minn. R. 7011.0715 emit the following pollutants in amounts less than 2,000 pounds per year each of (PM and opacity) NO SO,, PM, PM, VOCs (including hazardous air pollutant- containing VOCs), and ozone. TK 002 — Hazardous Waste Solvent TK 007 — Waste Solvent — Tank 3 (Overflow Tank) TK 012 — #2 Fuel Oil — Tank 12 TK 014 —Waste Solvent —Tank 10 TK 015 — Decant TK 016 — Sludge Blend Tank TK 017 — Sludge Feed Tank TK 018 — Waste Solvent — Tank 21 TK 019 — Waste Solvent — Tank 22 TK 020 — Waste Solvent — Tank 23 TK 021— Waste Solvent — Tank 24 TK 022 — Waste Solvent — Tank 25 TK 023 — Waste Solvent — Tank 26 TK 024 — Waste Solvent — Tank 27 TK 025 — Waste Solvent — Tank 28 4(B) Potential emissions of 5 2.28 lb /hr or actual emissions of 51.0 tpy for PM, PM NO,,, SO and VOCs. Cooling Towers Ash Handling Sludge Batch and Feed Tank Cleanout Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED AIR EMISSION PERMIT NO. 16300025 -002 This technical support document (TSD) is intended for all parties interested in the draft/proposed permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft /proposed permit. 1. General Information 1.1 Applicant and Stationary Source Location Corporate /Company Owner Stationary Source /Address SIC Code: 3999) 3M Company 3M Corporate Incinerator 3M Center, Bldg. 224 -5W -03 Chemolite Blvd Bldg. 111 St. Paul, MN 55144 Cottage Grove, Washington Count Contact: SumitraNess Phone: 651- 768 -1261 1.2 Facility Description The 3M Company ( Permittee) Cottage Grove Center (Facility) is located at 10746 Innovation Road, Cottage Grove, Minnesota. 3M operates a thermal treatment system under separate air quality and hazardous waste permits. The 3M Corporate Incinerator consists of a rotary kiln and a secondary combustion chamber (SCC) followed by a wet off -gas cleaning system. The off -gas cleaning system consists of a quench chamber, a subcooler, a particulate removal device known as the M1 module, a wet electrostatic precipitator (WESP), an induced draft fan, and an exhaust stack. Also located at this Facility are indoor and outdoor container storage areas, outdoor tank storage areas, a containment building for bulk solids storage, a tanker truck unloading area, outdoor trailer storage, indoor and outdoor material handling areas, and a rotary kiln incinerator with a secondary combustion chamber. These units provide treatment and storage of hazardous waste generated by 3M's operating divisions throughout North America, high BTU liquid solvent waste from outside sources, and regulated hazardous waste from Minnesota law- enforcement agencies. No disposal of hazardous waste is conducted at this Facility. The material storage and handling areas of the facility are permitted under a separate RCRA permit and are not covered under this air emissions permit. This permit authorizes the operation of the combustion system consisting of a rotary kiln and a secondary combustion chamber. The rotary kiln is 40 feet long, has a shell diameter of 14 feet 9 inches, and is designed as a primary combustion chamber. The secondary combustion chamber (SCC) is 60 feet high and has a shell diameter of 20 feet. It provides additional residence time to combust off -gases of organic wastes. The SCC burners have been removed, and the burner inlets are welded shut, which has reduced the overall capacity of the incinerator. An emergency vent stack is provided at the roof of the SCC. The combustion system has no boiler. This permit does not authorize the installation of a future boiler. Technical Support Document, Permit Action Number: 16300025 -002 Page 1 of 10 Date: 3/6/2012 The 3M Corporate Incinerator, which includes container and tanker storage areas, provides treatment and storage for business - related wastes generated by 3M's operating divisions throughout North America. The Incineration system is designed to handle a variety of wastes introduced through four separate feed systems. Materials can be fed to the rotary kiln by four means depending on the waste stream. Solids are fed through a bulk feed chute (pakfeeder and Komar shredder); pumpable liquids are fed through lances or the frontwall burner; sludge is fed through a lance from either the Building 145 sludge room or the Building 47 pump room; and direct burn wastes are fed through a lance. Pollution control is facilitated with several flue gas treatment devices. The incinerator exhaust gases are saturated and cooled in the quench chamber. Flue gases then pass through a subcooling tower and filtering module. Final pollution control is provided by a wet electrostatic precipitator. Flue gases are pulled through the system with an induced draft fan and exhausted through a 165 -foot stack to the atmosphere. Hazardous waste is shipped to the Facility via semi - trailers in 55- gallon steel drums, totes, plastic and fiber drums, pails, boxes, bags, portable tanks, and tanker trucks. The types of containerized wastes received include solids, gases in cylinders, pumpable sludges, organic liquids, and aqueous liquids. 1.3 Description of the Activities Allowed by this Permit Action This permit amendment is a reissuance of the operating permit, and a major amendment to allow additional sources of non -3M hazardous waste for incineration in the kiln. The additional outside sources will provide high Btu value liquid solvent waste. The facility will also be authorized to process regulated hazardous waste from Minnesota law- enforcement agencies. The specific wastes that may be received are specified in the Hazardous Waste Facility permit. (MND 006 172 969) Replacement standards for hazardous waste incinerators under 40 CFR § 63.1219 became effective on October 14, 2008. The permit was updated to reflect the new standards. The facility has also accepted lower limits on allowable mercury throughput and emissions. This accounts for a 33% reduction in hourly throughput and hourly emissions, and a 70% reduction in allowable yearly emissions. 1.4. Facility Emissions Table 1. Total Facility Limited Potential to Emit (PTE) Summary (tpy) Table 2. Facility Classification Classification PM/PMIO/ Synthetic Minor Minor PSD X Single All Mercury SO CO PM 2 . 5 SO Z NO a CO VOC Lead HAP HAPs (lb/ r) Total Facility 20.1 95 209 67.0 40.2 0.125 27.9 35.4 15.0 Limited PTE (HCI Total Facility Actual 9.93 0.34 62.0 3.2 25.9 0.01 HAPs not reported in 1.47 Emissions 2008) emission invento Table 2. Facility Classification Classification Ma'or /Affected Source Synthetic Minor Minor PSD X Part 70 Permit Program NO HCI, Total HAPs SO CO PM, PM T ,, PM,.,, Lead, VOC Part 63 NESHAP X Technical Support Document, Permit Action Number: 16300025 -002 Page 2 of 10 Date: 3/6/2012 2. Regulatory and /or Statutory Basis New Source Review (NSR) The facility has limits to keep it a synthetic minor source under NSR regulations. No changes are authorized by this permit that would affect this status. Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) There are no New Source Performance Standards applicable to the operations at this facility. National Emission Standards for Hazardous Air Pollutants (NESHAP) Portions of the facility are subject to the following NESHAPs (40 CFR pt. 63): • Subp. DD — NESHAPs from Off -Site Waste and Recovery Operations • Subp. 00 — National Emission Standards for Tanks — Level 1 • Subp. PP — National Emission Standards for Containers • Subp. EEE — NESHAPs from Hazardous Waste Combustors • Subp. ZZZZ — NESHAPs for Stationary Reciprocating Internal Combustion Engines Portions of the facility are subject to the following NESHAPs (40 CFR pt. 61): • Subp. V — National Emission Standards for Equipment Leaks Compliance Assurance Monitoring (CAM) The kiln (EU 008) has potential uncontrolled emissions of S0 that are greater than 100 tpy and are controlled by a Venturi Scrubber (CE 010); therefore the kiln is subject to CAM for S0 The Venturi Scrubber is also used to control HCl emissions. The kiln is also subject to 40 CFR 63, Subpart EEE, which specifies the monitoring requirements for the Venturi Scrubber. The CAM plan is attached to the TSD as Attachment 1. Environmental Review & AERA The proposed modification is not subject to environmental review, i.e. an Environmental Assessment Worksheet (EAW), and is not required to perform an Air Emissions Risk Analysis (AERA). Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance: • Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment • Minn. R. 7011.0610 Standards of Performance for Fossil -Fuel- Burning Direct Heating Equipment • Minn. R. 7011.1505 Standards of Performance for Storage Vessels • Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines • Minn. R. 7011.9990 Volatile Hazardous Air Pollutants Technical Support Document, Permit Action Number: 16300025 -002 Page 3 of 10 Date: 3/6/2012 Table 3. Regulatory Overview of the Facility Level Applicable Regulations Comments FC 40 CFR 63, Subpart DD NESHAPs from Off -Site Waste and Recovery Operations GP 001 40 CFR §61.242 Equipment leaks subject to Subpart V GP 002 40 CFR 63.920 Containers subject to Subpart PP GP 003 40 CFR 63.900 Tanks subject to Subpart 00 GP 004 140 CFR 63.685 Tanks sub to Subpart DD EU 008 40 CFR §63, Subpart EEE NESHAPs from Hazardous Waste Combustors Minn. R. 7011.0515 Indirect Heating Equipment Rule limit ensures facility is non -major for NSR Minn. R. 7011.0110, sub p. 2 General opacity rule EU 014 40 CFR §63, Subpart ZZZZ I Engine sub to Subpart ZZZZ 3. Technical Information 3.1 Calculations of Potential to Emit Detailed calculations were completed in support of permit limits and calculation of PTE. The detailed spreadsheets are stored in the Delta database. The results of the 2009 Comprehensive Performance Test (CPT) dictated new feedrate and operating limits. The replacement standards of 40 CFR §63, Subpart EEE also reduced allowable emissions. The calculations of allowable emissions were updated to reflect these changes. Many limits are listed in the permit in units of ppm. Conversion from ppm to lb /hr requires air flow rate and pollutant specific data of molecular weight and molar volume. Molar volume is calculated using the ideal gas law, and choosing a temperature and pressure. Stack pressure was chosen at 1 bar, stack temperature was found to range from approximately 130 °F to 170 °F. The minimum stack temperature and maximum air flow rate was used to represent worst case emissions estimates. Any stack temperature above 65 °F shows a PTE for NOx below 235 tpy; so it is unlikely that actual NOx emissions will ever approach PSD thresholds. Low - Volatile Metals (LVM) and Semi - Volatile Metals (SVM) emission limits The permit contains revised feedrate limits for LVM and SVM, as well as revised emission concentrations. The feedrate limits were calculated based on the worst -case removal efficiency demonstrated during the 2009 CPT, and the Maximum Theoretical Emission Concentration (MTEC) calculation to ensure continuous compliance with the emission concentration limits. Volatile Organic Compounds (VOCs) PTE calculations for VOCs were completed using a weighted average molecular weight based on the measured amounts of each component from the 2001 Trial Burn. It is unlikely that actual VOC emissions will ever approach PSD thresholds. 3.2 Fuel Comparison Emissions Analysis 3M has decreased the amount of liquid solvent waste it has generated throughout North America as a result of recycling efforts and reformulation of products. This decrease has required the use of natural gas to supplement the kiln in order to maintain the required temperatures. The Permittee prepared calculations compare the potential change in actual emissions as a result of burning liquid solvent waste instead of natural gas, by comparing the amount of natural gas burned in 2007, with an equivalent amount (BTU value) of liquid solvent waste burned, and looking at how the change affects the total emissions as reported in the 2007 emission inventory. 3M has accepted limits on the amount of outside solvent waste received (400,000 mmBtu/yr). A minimum BTU value for the fuel was assumed to be 5000 Btu /lb to represent the worst case increase in emissions when comparing to 2007 data. These calculations show worst case increases in particulate Technical Support Document, Permit Action Number: 16300025 -002 Page 4 of 10 Date: 3/6/2012 matter and VOCs of approximately 1.08 tpy (10.72°/x) and 0.053 tpy (0.20 %) respectively. These increases do not represent an increase in Potential to Emit and therefore do not represent an emissions increase under state and federal air quality regulations. 3.3 Applicability of NESHAPs 3.3.1 Subpart EEE 40 CFR Part 63, Subpart EEE — NESHAP from Hazardous Waste Combustors. The original standards for Subpart EEE were promulgated on September 30, 1999, and the replacement standards (current rule) were promulgated on October 12, 2005, and amended on October 28, 2008. For compliance with the replacement MACT standards, an existing source is defined as a source that has not commenced construction or reconstruction after April 20, 2004. 3M began constructing the replacement kiln September 1997, and therefore is classified as an existing source. EPA intended the requirements of the MACT rule to meet the obligations for hazardous waste combustor air emission standards under two environmental statutes, the Clean Air Act (CAA) and the Resource Conservation and Recovery Act (RCRA). Historically, the overlapping of CAA and RCRA requirements has resulted in the duplication of effort. One of the goals of the new MACT standard was to develop a permitting scheme that avoids duplication to the extent possible. The facility must have a RCRA permit that covers stack air emissions until the facility demonstrates compliance with the MACT standards. The facility will remain subject to the RCRA stack air emission permit until the RCRA permit is modified to delete those conditions. The facility must satisfy both sets of requirements during the relatively short period when both the RCRA and MACT stack air emission standards and associated requirements in the RCRA permit are effective. RCRA permit MND 006 172 969 is modified to delete those conditions. Where requirements address the same topic, the facility must meet the more stringent. RCRA section 1006(b) provides authority for the Administrator to eliminate the existing RCRA air emission standards to avoid duplication with the new MACT standards. EPA has chosen to defer RCRA controls on the air emissions to the part 63 MACT standards, which are incorporated into the Title V Permit. The Title V Permit will focus on the operation of the combustion unit (air emissions and related parameters) while the RCRA permit will continue to focus on basic hazardous waste management at the facility. Applicability of RCRA permitting requirements of 40 CFR 270.19, 270.22, 270.62, and 270.66 do not apply once a source demonstrates compliance with the standards in subpart EEE by conducting a Comprehensive Performance Test (CPT) and submitting a Notice of Compliance (NOC) to the permitting authority. The CPT was completed on October 16, 2009, and the NOC was submitted June, 2010. The Memorandum of Agreement (MOA) between the MPCA and US EPA, dated February 28, 2005, specifies that the enforcement authority of Subpart EEE remains with US EPA. The MPCA declined delegation of this standard. Part III, paragraph (13)(2) of the MOA. 3.3.2 Subpart DD 40 CFR Part 63, Subpart DD — NESHAP from Off -Site Waste and Recovery Operations. This NESHAP covers air emissions from units such as tanks, containers and equipment leaks. Many of the requirements referenced by subpart DD have an identical or very similar counterpart in the Part 264 RCRA regulations and these are listed below. In some cases the RCRA subpart does not apply if a corresponding air NESHAP Subpart applies, and in other cases RCRA allows the Permittee to demonstrate compliance with the RCRA Subpart by demonstrating compliance with the corresponding air NESHAP Subpart. Part 264 subpart CC says that the requirements of subpart CC do not apply if the units are covered under a corresponding CAA requirement; and Part 264 subpart BB says that owners of equipment subject to a corresponding CAA requirement may elect to determine compliance by documenting compliance with the relevant CAA Technical Support Document, Permit Action Number: 16300025 -002 Page 5 of 10 Date: 3/6/2012 provisions. MPCA will place the requirements of Part 63, subpart DD in the Title V permit and remove the corresponding requirements from the RCRA permit. MPCA plans to permit the facility such that units that have the potential to emit to the air will be covered under the air permit and potential leaks and spills to groundwater, surface water, or soils from units will be covered under the RCRA permit. • Part 63, subpart DD references 40 CFR 63, subpart PP for the management of containers, and the Permittee will demonstrate compliance with Part 63, subpart PP. The requirements of 40 CFR 264.1086, subpart CC do not apply according to 40 CFR 264.1080(b)(7). • Part 63, subpart DD references 40 CFR 63, subpart 00 for the management of Level 1 Tanks, and the Permittee will demonstrate compliance with Part 63, subpart 00. The requirements of 40 CFR 264.1086, subpart CC do not apply according to 40 CFR 264.1080(b)(7). • Part 63, subpart DD for the management of Level 2 Tanks, and the Permittee will demonstrate compliance with Part 63, subpart DD. • Part 63, subpart DD references 40 CFR 61, subpart V for management of Equipment Leaks, and the Permittee will demonstrate compliance with Part 61, subpart V to show compliance with 40 CFR 264, subpart BB. RCRA Part 264, subpart CC provides the authority to replace Part 264 requirements with corresponding CAA requirements. 40 CFR 264.1080(b)(7) says "the requirements of this subpart do not apply to the following waste management units at the facility: A hazardous waste management unit that the owner or operator certifies is equipped with and operating air emission controls in accordance with the requirements of an applicable CAA regulation codified under 40 CFR part 60, part 61, or part 63." The Permittee must fully comply with all applicable CAA and RCRA permit limits. Where two or more operating limitations apply, the most stringent operating limitations take precedence. Pursuant to 40 CFR § 264.1080(b)(7), the requirements of Part 264 Subpart CC are not included in the U.S. EPA portion of the Permittee's RCRA permit. The Permittee is required to maintain compliance with the applicable requirements of the CAA regulations at 40 CFR parts 60, 61, and 63. Should the CAA regulations change such that they no longer apply to any unit handling hazardous waste that would have been subject to Part 264 Subpart CC, that unit will become subject to Subpart CC. The RCRA permit will be modified accordingly to include Subpart CC requirements after the Permittee applies to MPCA for a permit modification to include Subpart CC. The Permittee must record and maintain on site the following information for each hazardous waste management unit for which 40 CFR 264.1080(b)(7) was invoked: (1) Certification that the waste management unit is equipped with and operating air emission controls in accordance with the requirements of an applicable CAA regulation codified under 40 CFR parts 60, 61, or 63; (2) Identification of the specific requirements codified under 40 CFR parts 60, 61, or 63 with which the waste management unit is in compliance. 40 CFR § 264.1064(m) allows owners of any of the equipment subject to Part 264, subpart BB that is also subject to the CAA regulations at 40 CFR Parts 60, 61, or 63 to elect to determine compliance with Subpart BB by documenting compliance with the relevant provisions of 40 CFR Parts 60, 61, or 63. Such documentation shall be kept on file by the Permittee and made available on request by EPA. MPCA will place the requirements of Part 61, subpart V in the Title V Permit. Part 264, subpart BB provides for the Permittee to demonstrate compliance with Subpart BB through Part 61, subpart V. Also, in the General Provisions of RCRA, the Act provides the guidance on how to integrate RCRA with other Acts. The provisions call for the avoidance of duplication with other Acts including the CAA. Technical Support Document, Permit Action Number: 16300025 -002 Page 6 of 10 Date: 3/6/2012 "RCRA General Provisions; Sec. 6905. - Application of chapter and integration with other Acts (b) Integration with other Acts (1) The Administrator shall integrate all provisions of this chapter for purposes of administration and enforcement and shall avoid duplication, to the maximum extent practicable, with the appropriate provisions of the CAA (42 U.S.C. 7401 et seq.), the Federal Water Pollution Control Act ... and such other Acts of Congress as grant regulatory authority to the Administrator. Such integration shall be effected only to the extent that it can be done in a manner consistent with the goals and policies expressed in this chapter and in the other acts referred to in this subsection." Also, in the General Provisions of RCRA, the Act provides for protection of ambient air quality through compliance with the CAA. "Sec. 6907. - Solid waste management information and guidelines (a) Guidelines: Within one year of October 21, 1976, and from time to time thereafter, the Administrator shall, in cooperation with appropriate Federal, State, municipal, and intermunicipal agencies, and in consultation with other interested persons, and after public hearings, develop and publish suggested guidelines for solid waste management. Such suggested guidelines shall... (2) not later than two years after October 21, 1976, describe levels of performance, including appropriate methods and degrees of control, that provide at a minimum for... (D) protection of ambient air quality through compliance with new source performance standards or requirements of air quality implementation plans under the CAA, as amended (42 U.S.C. 7401 et seq.) ". 3.4 Periodic Monitoring and CAM In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. For CAM, the Permittee submitted a CAM proposal as required by 40 CFR § 64.3. It can be found in Attachment 1 to this TSD. In evaluating the monitoring included in the permit, the MPCA considers the following: • The likelihood of violating the applicable requirements; • Whether add -on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already available for the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and • The kind of monitoring found on similar units elsewhere. The table below summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate. Technical Support Document, Permit Action Number: 16300025 -002 Page 7 of 10 Date: 3/6/2012 Table 7. Periodic Monitoring EU /GP Requirement Additional Discussion rule basis Monitorin GP 001 40 CFR 61.242 Leak detection Compliance with Subpart V will be determined by Equipment monitoring, visual review of records, review of performance test results and Leaks inspections, inspections. All of the equipment subject to Subpart V Subject to operating is also subject to Part 264 Subpart BB. Subpart BB Subpart V standards allows that if any of the equipment subject to Subpart BB is also subject to the CAA regulations at 40 CFR Parts 60, 61, or 63, then 40 CFR Part 264.1064(m) allows the Permittee to elect to determine compliance with Subpart BB by documenting compliance with the relevant provisions of 40 CFR Parts 60, 61, or 63. Such documentation of compliance with Part 61 Subpart V shall be kept at the facility and made available for inspection. GP 002 40 CFR 63.920 Operating Permittee shall follow the packaging and handling Containers standards requirements and perform inspections according to Subject to Subpart PP. Subpart PP GP 003 40 CFR 63.900 Design Criteria, The Permittee shall follow the design criteria and test Tanks Inspections and methods and procedures of Subpart 00. Subject to Performance Subpart 00 Testing GP 004 40 CFR 63.680 Design Criteria The Permittee shall follow the design criteria and Tanks and Inspections inspection requirements of Subpart DD. Subject to Subpart DD EU 008 40 CFR 63, Subpart Recordkeeping, This unit incorporates feedrate limits, continuous Replacement EEE, Emissions Performance emission monitoring systems (OEMs) and other Rotating Limits, Feedrate Testing, continuous monitoring systems (CMS) such as Kiln Limits, Operating Operating thermocouples, pressure transducers, and flow meters. Limits Requirements, Comprehensive performance tests (CPTs) are required Monitoring every 5 years, and confirmatory performance tests are required 2.5 years after each CPT. Minn. R. Performance Performance tests are required to verify emission 7017.2020, subp. 1 Testing factors used for calculating emissions inventory. Factors must be used from tests that were performed in the last 10 years. The last test was March 28, 2001. The updated tests are required for NO,,, SO F, IH', and opacity. EU 014 SO, <_ 0.5 none The emergency generator uses natural gas; therefore, lbs /MMBtu the likelihood of violating either of the emission limits Opacity 5 20% is very small. The Permittee can demonstrate that this unit will continue to operate such that emissions are (Minn. R. well below the emission limits by only burning 7011.2300) natural gas. Since this is a permit condition, the semi- annual deviations report will document any deviations from this condition. Design based PTE for the generator, using AP -42, is 0.084 lb /MMBtu compared to the rule limit of 0.5 lb /NMffltu. Technical Support Document, Permit Action Number: 16300025 -002 Page 8 of 10 Date: 3/6/2012 3.5 Insignificant Activities The 3M Corporate Incinerator has several operations which are classified as insignificant activities. These are listed in Appendix C to the permit. 3.6 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. 3.7 Comments Received Public Notice Period: March 7, 2012 — April 23, 2012 EPA 45 -day Review Period: March 7, 2012 — April 23, 2012 4. Permit Fee Assessment This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1 to the changes that are covered by the reissuance application. However, the permit action rolls in one additional permit application to which fees do apply. Attachment 4 to this TSD contains the MPCA's assessment of Application and Additional Points used to determine the permit application fee as required by Minn. R. 7002.0019. The changes covered are for the major amendment application. The action also includes the incorporation of a NESHAP, however this was an existing standard that applied to the facility and is not a chargeable activity (i.e., the standard was not triggered by the modifications requested in the permit applications — it falls under a permit reopening being incorporated in the reissuance). 4. Conclusion Based on the information provided by 3M, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 16300025 -002 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Trevor Shearen (permit writer /engineer) Bob Beresford (enforcement) Curt Stock (stack testing) Bruce Braaten (peer reviewer) AQ File No. 23AI; DQ 2804, 2440, 1230 Attachments: 1. CAM Plan 2. Facility Description and CD -01 Forms (in Delta) 3. Calculations (in Delta) 4. Points Calculator (in Delta) Technical Support Document, Permit Action Number: 16300025 -002 Page 9 of 10 Date: 3/6/2012 Attachment 1: CAM Plan AQ ID: 16300025, 3M Cottage Grove Corporate Incinerator Unit(Pollutant for CAM Plan: EU 008, Replacement Rotating Kiln /SO2 L BACKGROUND A. Emission Unit: Replacement Rotating Kiln — E0008, CE010 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations /Emission Limits: Permit limit to avoid major source of PSD for SO2 • 95 tons /yr; Monitoring Requirements: (Established during most recent performance test. Next performance test to re- establish or change requirements is scheduled for 10/09.) • Minimum Blowdown from Quench and Subcooler combined: 192 gpm using 1 -HRA • Maximum Quench Exit Temperature: 182F • Subcooler Recirculation Water Flow: 3,200 gpm using 1 -HRA • Subcooler Water Pressure: 19.4 psi using 1 -HRA • Minimum Subcooler pH: pH of 1.2 using 1 -HRA C. Control Technology (pollutant controlled) CE010 — Venturi Quench + Subcooler used to control HCI for MACT EEE and also removes SO2. II. MONITORING APPROACH 3M Company proposes to use compliance with the current permit operating limits in the permit to satisfy CAM for SO2 for the Rotating Kiln. The facility is required to operate Continuous Monitoring Systems (CMSs) to monitor the above operating limits as part of the current Title V permit. 3M Company will continue to operate the CMSs. 1. Indicator: Compliance with the permit limits listed above. 2. Indicator Range: Permit Limits listed above 3. Performance Criteria: • Data Representativeness — Indicator ranges established in current stack testing. • Verification of Operational Status — CMS requirements in the current permit will address operational status. • QA/QC — CMS requirements in the current permit will address QA/QC. • Monitoring Frequency —continuous and 1 -HRA 1 -HRA — 1 Hour Rolling Average Technical Support Document, Permit Action Number: 16300025 -002 Page 10 of 10 Date: 3/6/2012 DRAFT PERMIT FOR 3M COMPANY 3M COTTAGE GROVE CORPORATE INCINERATOR MND 006172969 FOR A HAZARDOUS WASTE STORAGE AND TREATMENT FACILITY LOCATED AT 10746 INNOVATION ROAD COTTAGE GROVE, MINNESOTA 55016 April XX, 2012 MINNESOTA POLLUTION CONTROL AGENCY 520 LAFAYETTE ROAD NORTH ST. PAUL, MINNESOTA 55155 -4194 TABLE OF CONTENTS Page PART I. DESCRIPTION OF FACILITY .................................................. ............................... 1 A. REGULATED/PERMITTED UNITS ................................................ ............................... 1 PART II. AUTHORIZED HAZARDOUS WASTE MANAGEMENT ... ............................... 5 A. RESERVED ........................................................................................... ..............................5 B. SPECIFIC HAZARDOUS WASTES AUTHORIZED TO BE MANAGED ................ 5 C. STORAGE OF HAZARDOUS WASTE IN CONTAINERS (DRUMS) ....................... 5 D. STORAGE OF HAZARDOUS WASTE IN TANKS ....................... ............................... 9 E. MISCELLANEOUS UNIT ................................................................. ............................... 9 F. CONTAINMENT BUILDING ........................................................... ............................... 9 G. TREATMENT OF HAZARDOUS WASTE IN INCINERATOR .. ............................... 9 PART III. OPERATING CONDITIONS ................................................... .............................10 A. OPERATION AND MAINTENANCE .............................................. .............................10 B. NOTICE TO GENERATORS ............................................................ .............................19 C. RECEIPT OF UNAUTHORIZED WASTES ................................... .............................19 D. RESERVED .......................................................................................... .............................20 E. GENERAL WASTE ANALYSIS ..................................................... ............................... 20 F. PERSONNEL TRAINING ................................................................ ............................... 20 G. HANDLING MANIFESTS ............................................................... ............................... 20 H. MANIFEST DISCREPANCIES ....................................................... ............................... 20 I. MONITORING .................................................................................... .............................21 J. STORAGE OF IGNITABLE, REACTIVE, AND INCOMPATIBLE WASTES....... 21 K . INSPECTIONS .................................................................................. ............................... 22 L. SECURITY ........................................................................................... .............................23 M . LIGHTING ........................................................................................... .............................23 N. FINANCIAL ASSURANCE FOR CLOSURE ................................ ............................... 23 O. LIABILITY COVERAGE ................................................................ ............................... 23 P. WASTE PROCESSING .................................................................... ............................... 24 Q. RESERVED .......................................................................................... .............................24 R. SPECIAL CONDITIONS FOR EXISTING UNITS ...................... ............................... 24 PART IV. EMERGENCY PROCEDURES ............................................. ............................... 26 A. IMPLEMENTATION OF CONTINGENCY PLAN ..................... ............................... 26 B. AMENDMENT OF CONTINGENCY PLAN ................................. ............................... 26 C. PREPAREDNESS AND PREVENTION ........................................ ............................... 26 D. EMERGENCY COORDINATOR ................................................... ............................... 27 E. RESPONSE TO SPILLS/LEAKS/RELEASES FROM REGULATED UNITS ........ 28 F. RESPONSE TO OTHER SPILLS/LEAKS/RELEASES FROM NON - REGULATED UNITS................................................................................................. ............................... 30 TABLE OF CONTENTS Page G. NOTIFICATION TO MPCA REGARDING SPILLS/LEAKS/RELEASES OF HAZARDOUSWASTE ..................................................................... ............................... 30 H. ADDITIONAL EMERGENCY COORDINATOR DUTIES AND NOTIFICATION TO OTHER AGENCIES .................................................................. ............................... 33 I. CONTAINMENT MEASURES ....................................................... ............................... 34 J. POST EMERGENCY CLEANUP ................................................... ............................... 34 K. STARTUP OF OPERATIONS ......................................................... ............................... 34 L. POST EMERGENCY REPORTING .............................................. ............................... 35 M. OPERATING RECORD ................................................................... ............................... 35 N. EMERGENCY VENT STACK ( DUMPSTACK) ........................... ............................... 35 PART V. RECORDKEEPING REQUIREMENTS ................................ ............................... 36 A. PLANS TO BE MAINTAINED AT THE FACILITY ................... ............................... 36 B. OPERATING RECORD ................................................................... ............................... 36 C. PERSONNEL RECORDS ................................................................. ............................... 37 D. INSPECTION RECORDS ................................................................ ............................... 38 E. MONITORING AND TESTING RECORDS ................................. ............................... 38 F. RETENTION AND DISPOSITION OF RECORDS ...................... ............................... 39 PART VI. REPORTING REQUIREMENTS .......................................... ............................... 40 A. REPORTING NONCOMPLIANCE ................................................ ............................... 40 B. REPORTING PLANNED CHANGES ............................................ ............................... 40 C. ANNUAL REPORTING REQUIREMENTS ................................. ............................... 40 D. NOTIFICATIONS AND SUBMITTALS ON AIR EMISSIONS FROM EQUIPMENT LEAKS; TANKS, SURFACE IMPOUNDMENTS, AND CONTAINERS; AND PROCESS VENTS ...................................... ............................... 41 E. CERTIFICATION AND SIGNATORY REQUIREMENTS ........ ............................... 41 F. SUBMITTAL OF WRITTEN REPORTS ....................................... ............................... 42 PARTVII. CLOSURE ............................................................................... ............................... 43 A. NOTIFICATION OF CLOSURE .................................................... ............................... 43 B. CLOSURE PLAN .............................................................................. ............................... 43 C. TIME ALLOWED FOR CLOSURE ............................................... ............................... 43 D. CERTIFICATION OF CLOSURE .................................................. ............................... 43 PART VIII. CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS. 44 PART IX. GENERAL CONDITIONS ...................................................... ............................... 45 A. NO RELEASE FROM LIABILITY ................................................. ............................... 45 B. THIRD PARTY LIABILITY ............................................................ ............................... 45 C. FUTURE RULES ............................................................................... ............................... 45 D. PROPERTY RIGHTS ....................................................................... ............................... 45 TABLE OF CONTENTS Page E. OBLIGATION TO ENFORCE ........................................................ ............................... 45 F. LIABILITY/RESPONSIBILITY ..................................................... ............................... 45 G. DEFENSE UNDER OTHER STATUTES AND RULES ............... ............................... 46 H. MINIMUM STANDARDS ................................................................ ............................... 46 I . DUTY TO COMPLY ......................................................................... ............................... 46 J. POLLUTION PREVENTION .......................................................... ............................... 46 K . FALSE STATEMENTS .................................................................... ............................... 46 L. DUTY TO PROVIDE INFORMATION ......................................... ............................... 47 M. INSPECTION AND ENTRY ............................................................ ............................... 47 N. DUTY TO MITIGATE ..................................................................... ............................... 47 O . BANKRUPTCY ................................................................................. ............................... 47 P. MODIFICATION, REVOCATION, AND REISSUANCE OF THIS PERMIT ........ 48 Q. OPERATION DURING REISSUANCE PERIOD ......................... ............................... 48 R. CONTINUATION OF EXPIRED PERMIT ................................... ............................... 48 S. TRANSFER OF PERMITS .............................................................. ............................... 48 T. SEVERABILITY ............................................................................... ............................... 49 U. EMERGENCY PERMITS ................................................................ ............................... 49 V. AUTHORIZED SIGNATURES ....................................................... ............................... 49 PART X. REVIEW OF SUBMITTALS AND EXTENSION OF SCHEDULES ................ 50 A. REVIEW OF SUBMITTALS ........................................................... ............................... 50 B. EXTENSION OF SCHEDULES ...................................................... ............................... 50 PART XI. LAND DISPOSAL REQUIREMENTS .................................. ............................... 52 A. GENERAL CONDITIONS ............................................................... ............................... 52 B. TESTING AND RELATED REQUIREMENTS ............................ ............................... 52 C. STORAGE PROHIBITIONS ........................................................... ............................... 53 D. BLENDING OF METAL WASTES ................................................ ............................... 53 PART XII. AIR EMISSIONS OF ORGANIC COMPOUNDS .............. ............................... 54 A. COORDINATION WITH THE CLEAN AIR ACT ....................... ............................... 54 B. EQUIPMENT LEAKS ...................................................................... ............................... 54 C. TANKS, SURFACE IMPOUNDMENTS, AND CONTAINERS .. ............................... 55 D. PROCESS VENTS ............................................................................. ............................... 56 E. INCINERATOR ................................................................................. ............................... 57 F. NOTIFICATION OF REGULATED ACTIVITY ......................... ............................... 57 PART XIII. INCINERATOR PERFORMANCE STANDARDS .......... ............................... 58 APPENDICES APPENDIX I — FACILITY MAPS APPENDIX II — LIST OF HAZARDOUS WASTE STORED OR TREATED STATE OF MINNESOTA POLLUTION CONTROL AGENCY HAZARDOUS WASTE STORAGE AND TREATMENT FACILITY PERMIT FOR 3M COMPANY 3M COTTAGE GROVE CORPORATE INCINERATOR EPA ID NO. MND006172969 In accordance with the provisions of Minn. Stat. chs. 115 and 116, Minn. R. 7001.0010 to 7001.0730, and Minn. R. 7045.0020 to 7045.1400, a Hazardous Waste Storage and Treatment Facility Permit (Permit) is hereby reissued to 3M Company for, a hazardous waste incinerator facility located at 3M Cottage Grove Center, 10746 Innovation Road, Cottage Grove, Washington County, Minnesota (the Facility). This Hazardous Waste Facility Permit has been prepared based upon the information provided by 3M Company's most recent Permit Application (Part A and Part B) dated December 18, 2009, including revisions received through February, 2012. The Permit Application, as revised, is referenced throughout this Permit and as such, is an integral and enforceable part of this Permit. 3M Company is the owner and operator and is hereinafter referred to as the Permittee or 3M. Specific operating, emergency, record keeping, reporting, and general conditions apply to the Facility which contains all permitted regulated units. However, for the purposes of corrective action, the Facility includes all property owned by the Permittee, located at the above location and delineated in Appendix I of the Permit. The Facility location is at latitude: 92 degrees, 55 minutes, 0 seconds; longitude: 44 degrees, 47 minutes, 30 seconds; Section: 34, Township: T27N; Range: R21 W. Hazardous waste is generated on site and off site; hence the Facility is considered an off -site Facility. This Permit authorizes the Permittee to conduct the following hazardous waste management activities: 1. Storage of hazardous waste in Tanks 2. Storage of hazardous waste in Containers 3. Storage of hazardous waste in a Containment Building 4. Operation of a Miscellaneous Unit/Waste Shredder 5. Operation of a hazardous waste Incinerator The Permittee must at all times conduct its hazardous waste management activities in accordance with the terms and conditions of this Permit and any other requirements imposed by law or Minnesota Rules. This Permit shall become effective on the date of reissuance by the manager of the Minnesota Pollution Control Agency's (MPCA) Land and Air Compliance Section of the Industrial Division. The original Permit was issued on March 29, 1989. This Permit is effective until five years from date of reissuance or until terminated, revoked, or modified by the MPCA, whichever comes first. To obtain a future reissued Permit, the Permittee shall submit an application to the MPCA for reissuance of the Permit. In accordance with Minn. R. 7001.0040, subp. 3, an application for reissuance of this Permit must be submitted to the MPCA no later than 180 calendar days prior to the expiration date of this Permit. DATE OF REISSUANCE: Jeff T. Connell, Manager Land & Air Compliance Section Industrial Division PART I. DESCRIPTION OF FACILITY The Facility is located at 10746 Innovation Road, Cottage Grove, Minnesota. This Facility is both owned and operated by 3M Company which produces a wide variety of products including adhesives, tapes, resins, chemicals, polymeric films and extrusions, abrasive products, and hollow glass bead extenders. Hazardous waste is shipped to the Facility by semi - trailers in 55- gallon steel drums, totes, plastic and fiber drums, pails, boxes, bags, cylinders, portable tanks, and by tanker trucks. The types of containerized wastes received include bulk organic and aqueous liquids and bulk solids; containerized solids, sludges, gases, and organic and aqueous liquids; and pumpable sludges. Semi - trailers loaded with containers are transferred to the dock stalls of Buildings 47, 60 and 145 for unloading; tanker trucks are unloaded at Buildings 77and 136. Located at the Facility are indoor and outdoor container storage areas, indoor and outdoor tank storage areas, a containment building, a rotary kiln incinerator, and two miscellaneous hazardous waste management units (Komar shredder and the Decontamination Area). These units provide storage and /or management of hazardous and non hazardous wastes. Operation of a rotary kiln incinerator and associated air pollution control equipment is addressed by both this Permit and the Title V Air Emission Facility Permit No. 16300025 -002 issued by the MPCA on (effective date of Air Permit). A. REGULATED/PERMITTED UNITS 1. Indoor and Outdoor Container Storage a. Buildings 47, 60 and 145 -- Outdoor Waste Receiving Dock Stalls - Material Handling Because trailers containing hazardous waste are parked in the receiving docks for longer than 24- hours, the exterior docks are permitted hazardous waste storage areas. Buildings 47, 60, and 145 have 16 dock stalls; each trailer can hold 88 to 96 containers (or the equivalent) depending upon the trailer and container sizes. The docks are constructed of coated concrete and provide secondary containment. See Part II.C. of the Permit for storage capacities, and Vol. 1, Section S of the Permit Application for a more detailed description of this hazardous waste storage area. b. Building 47 -- Indoor Material Handling Within Building 47 there is a storage and staging area, a former pak- feeder area, and a sludge pump room all used for storage (longer than 24 hours) of hazardous waste. All floors in these storage areas are coated concrete. Secondary containment is provided through curbed /diked flooring with additional sumps and trenches. See Part II.C. of the Permit for storage capacities and Vol. 1, Section S 1 of the Permit Application for a more detailed description of this hazardous waste storage area. 1 of 67 EPA ID # MND006172969 April 2012 C. Building 60 -- Indoor Material Handling Within Building 60 there is a receiving /staging (longer than 24 -hour storage) area, six storage areas, and a drum inspection and sampling area. All floors in these storage areas are coated concrete. Secondary containment is provided through curbed /diked flooring with additional sumps and trenches. See Part II.C. of the Permit for storage capacities and Vol. 1, Section S 1 of the Permit Application for a more detailed description of this hazardous waste storage area. d. Building 145 -- Indoor Material Handling Within Building 145 there are three floors containing ten (10) separate container storage areas. On the main floor hazardous waste storage is permitted in the following areas: Direct burn room, sludge room, drum storage area, two drum handling areas, drum inspection area and menu burn area. On the second floor, storage is permitted in the shredder staging area. On the lower level, storage is allowed in two staging areas called Area 1 and Area 2. See Part II.C. of the Permit for storage capacities and Vol. 1, Section S1 of the Permit Application for a more detailed description of this hazardous waste storage area. e. Building 77 -- Outdoor Covered Material Handling Building 77 consists of a covered dock stall area for storage of two tanker trucks and a container storage area. Waste gases or liquids are also unloaded in this area and injected directly into the incinerator. This area is also used for staging containers for off -site shipment, or to unload semi - trailers, that are suspected of having a leaking drum. The floor is coated concrete. See Part II.C. of the Permit for storage capacities and Vol. 1, Section S 1 of the Permit Application for a more detailed description of this hazardous waste storage area. f. Building 136 -- Tanker Truck Unloading. Building 136 consists of an indoor building for storage of containers and for storage of two tanker trucks. Liquid wastes are analyzed for compatibility, and then pumped into one of the outdoor storage tanks prior to incineration or shipment to an off -site facility. See Part II.C. of the Permit for storage capacities and Vol. 1, Section S 1 of the Permit Application for a more detailed description of this hazardous waste storage area. g. Outdoor Trailer Storage Lots There are currently nine (9) trailer storage lots in use at the Facility. Lots A, B, C, D, E, F, J, K and L are currently used for storage of hazardous waste in semi - trailers. 3M is authorized to construct lot M for the storage of hazardous waste in semi - trailers. Lot C and the south half of Lot A may also be used to store hazardous waste in semi - trailers and tanker trucks. Secondary containment of hazardous wastes stored in trailers in Lots B, D, E, F, J, K, L, M and the portion of lot A which is lacking concrete containment shall be provided by using internal semi - trailer steel containment liners. See Part II.C. of the Permit for storage capacities and Vol. 1, Section S1 of the Permit Application for a more detailed description of this hazardous waste storage area. 2. Tank Storage. All storage tanks listed in a. and b. below are "aboveground tanks" as defined in Minn. R. 7045.0020, subp. la. These tanks are currently used in a manner described below. Any change in the use of any tank must be approved in writing by the Commissioner prior to any change in use. 2 of 67 EPA ID # MND006172969 April 2012 Outdoor storage in tanks consists of ten (10) Tank Farm storage tanks: Tanks Purpose 200,000 gallon waste solvent storage tank Accept liquid waste for storage from a [Tank #1] tanker truck or Tank Farm storage tank. 10,000 gallon Decant Tank Accept liquid waste for storage and phase [Tank #20] separation from tanker truck or hazardous waste storage tanks. Eight 18,360 gallon tanks Accept liquid waste for storage from [Tanks #21428] tanker truck or hazardous waste storage tanks, and feed solvent waste to the kiln. These tanks are used to store and blend liquid hazardous wastes prior to incineration or shipment to an off -site facility. Each tank has a primary purpose, but any of the tanks may store any waste code treated at the incinerator that is listed in Appendix II of this Permit. Secondary containment, except for Tank #1, is provided by coated concrete containment basins. Secondary containment for Tank #1 is constructed of steel plate. All tanks have a high level alarm as a method of overfill prevention. Each diked secondary containment volume exceeds the volume of the largest tank within the dike, plus sufficient freeboard capacity for rainfall. Tank #1 is equipped with a flare that is required to be operated according to the requirements of 40 CFR Part 63 Subpart DD, as required by the Air Emissions Permit No. 16300025 -002. All tank systems including piping and ancillary equipment are required to be inspected daily and the results of these inspections are required to be logged daily. See Part II.D. of the Permit for storage capacity, and Vol. 1, Section S2 of the Permit Application for a more detailed description of tank storage. b. Indoor process tanks consists of two (2) tanks Tanks 2,150 gallon Sludge Batch Tank Purpose: Accepts pumpable /pourable wastes that are transferred from containers, outdoor storage tanks or from tanker trucks. 2,150 gallon Sludge Feed Tank Accepts pumpable /pourable wastes that are transferred from containers or from the Sludge Batch Tank, from outdoor storage tanks or from tanker trucks. These tanks are installed in the lower level of Building 145 and are used to accumulate, blend and feed waste to the incinerator. Secondary containment is provided by the epoxy- coated floor of Building 145 and overflow trenches along the walls. 3 of 67 EPA ID # MND006172969 April 2012 3. Miscellaneous Units The term "miscellaneous unit" is defined in Minn. R. 7045.0020, subp. 58a. Minn. R. 7035.0539 establishes standards for miscellaneous units that store or treat hazardous waste. One miscellaneous unit authorized by this Permit is a waste shredder that shreds hazardous and non - hazardous wastes and then feeds the shredded wastes into the incinerator. It is called the Komar shredder after the manufacturer. The Komar shredder is described in Section 54.2 of the Permit Application. The other miscellaneous unit authorized by this Permit is the Decontamination Area used for decontaminating equipment and parts prior to shipment off site. The Decontamination Area is described in Section S5 of the Permit Application. 4. Indoor Bulk Solids Storage Containment Building #181 The Containment Building is 20 feet wide by 34 feet long and is approximately 26 feet high. It has a coated concrete floor. This building is used primarily to store ash and slag generated by the incineration process. Ash and slag is stored here prior to shipment off site for hazardous waste landfill disposal. This building may also be used to store bulk solids and contaminated soils prior to incineration, subject to the limitations and requirements of this Permit. More detailed description of the design of the building is found in Vol. 1, Section S3 of the Permit Application. 5. Incinerator This Permit authorizes the operation of an incinerator consisting of a rotary kiln and a secondary combustion chamber. The rotary kiln is 40 feet long, has a shell diameter of 14 feet, 9 inches, and is designed as a primary combustion chamber. The secondary combustion chamber is 60 feet high and has a shell diameter of 20 feet. It provides additional residence time to combust off -gases of organic wastes. An emergency vent stack is provided at the roof of the secondary combustion chamber. The combustion system is provided with an air pollution control system that includes a quench chamber, a subcooler, a filtering module (MI), a wet electrostatic precipitator (WESP), an induced draft fan, and a stack. 4 of 67 EPA ID # MND006172969 April 2012 PART II. AUTHORIZED HAZARDOUS WASTE MANAGEMENT A. RESERVED B. SPECIFIC HAZARDOUS WASTES AUTHORIZED TO BE MANAGED 1. The Permittee is authorized to manage, under the conditions of this Permit, hazardous wastes generated by 3M operations in North America and 3M wastes from vendor facilities that manufacture, process, or manage 3M materials and products or recycle 3M materials and containers in North America ( "3M Sources "). A complete list of hazardous waste codes authorized to be managed is provided in Appendix II. 2. The Permittee is also authorized to manage, under the conditions of this Permit, bulk hazardous wastes with fuel value from non -3M sources within the United States that have one of the following waste codes: D001,17001, F002, F003, F005. 3M is limited to processing a maximum of 400,000 Million BTUs per year of hazardous wastes from non -3M sources. 3M is prohibited from accepting payment or other compensation for management of wastes generated by non -3M sources. 3. The Permittee is also authorized to manage, under the conditions of this Permit, controlled substance wastes, as defined in 21 CFR Part 1308, from Minnesota law enforcement agencies that have been seized or collected as a result of law enforcement activities ( "Law Enforcement Wastes "). 3M shall develop and maintain internal procedures for 3M and instructions for law enforcement agencies on how to manage these wastes. These procedures and instructions shall be submitted to MPCA for review and approval. Wastes from Minnesota law enforcement agencies are not included as a part of the 400,000 Million BTU's per year of hazardous wastes from non -3M sources. 4. The Permittee is also authorized to manage any hazardous residue and contaminated soil, water, or debris generated from a spill cleanup response action at 3M operations in North America. Notification and reporting requirements in Part IV (Emergency Procedures) of this Permit must be followed for spills or releases at the Facility. C. STORAGE OF HAZARDOUS WASTE IN CONTAINERS (DRUMS) 1. The Permittee is authorized to store in containers hazardous waste having the waste codes specified in Appendix II of the Permit. 2. The Permittee may store hazardous wastes in the following approved hazardous waste container storage areas as indicated in the following tables. 5 of 67 EPA ID # MND006172969 April 2012 Storage capacities are based on a trailer storage capacity of 88 drums and 50 gallons per drum. Actual container types and capacities may vary, but maximum total waste volumes shall not change. 6 of 67 EPA ID # MND006172969 April 2012 MAXIMUM MAXIMUM SECONDARY STORAGE STORAGE CONTAINMENT LOCATION CAPACITY CAPACITY VOLUME (Drums) (Gallons) (Gallons) Trailer Storage Lots Lot A 9, 152 drums or 571,000 North half provided by 4,400 drums (north) trailer liners; South half and provided by coated 54 tankers (south) concrete and sump (capacity 340,665 gallons) Lot B 616 30,800 Provided by trailer liners Lot C 3,520 drums or 260,000 Provided by coated 40 tankers concrete and sump (capacity 209,000 gallons) Lot D 5,456 272,800 Provided by trailer liners Lot E 5,896 294,800 Provided by trailer liners Lot F 5,104 255,200 Provided by trailer liners Lot J 6,600 330,000 Provided by trailer liners Lot K 440 22,000 Provided by trailer liners Lot L 1,408 70,400 Provided by trailer liners Lot M 8,448 422,400 Provided by trailer liners Total 46,640 drums or 2,529,400 38,368 drums and gallons _ 94 tankers 6 of 67 EPA ID # MND006172969 April 2012 Main Floor Area 1 — Direct Burn Room MAXIMUM MAXIMUM SECONDARY Area 2 — Sludge Room STORAGE STORAGE CONTAINMENT LOCATION CAPACITY CAPACITY VOLUME (Outside Sludge Room by (Drums)* (Gallons) (Gallons) Buildings 47 and 60 Dock Stalls 1,056 52,800 Provided by trailer liners Building 47 Drum Storage Pak - feeder Area 48 2400 264 Pump Room 32 1,600 1,145 Staging and Storage 500 25,000 4,326 Total Building 47 580 29,000 5,735 Building 60 Drum Storage - Receiving Area 240 12,000 3,070 Storage Area 1 16 800 93 Storage Area 2 20 (10) 1,000 58 Storage Area 3 20 (10) 1,000 57 Storage Area 4 52 (25) 2,600 139 Storage Area 5 20 (10) 1,000 58 Storage Area 6 60 (15) 3,000 84 Drum Inspection/Sampling Area 34 1,700 489 (sum of areas 1 -6) Total Building 60 462 (70) 23,100 3559 Building 145 Drum Storage Dock Stalls (4 trailer spaces) 352 17,600 Coated concrete & sump Main Floor Area 1 — Direct Burn Room 32 1,600 310 Area 2 — Sludge Room 48 2,400 1,310 Area 3 — Drum Storage 92 4,600 1,180 (Outside Sludge Room by Conveyors RR, ZZ) Area 4 — Pak Drum Handling 24 1,200 490 Conveyors (Al, A2, B1, 132) Area 5 — Pak Drum Inspection 4 200 785 Conveyors (Cl, C2, D, E) 7 of 67 EPA ID # MND006172969 April 2012 LOCATION Building 145 Main Floor (coat.) Area 6 — Pak Drum Directing Conveyors (F, S) Area 7 — Drum storage and Pak/Komar Queue Conveyors (1-11 -4, J1-4, K1 -4, L, M, N, O, P, Q, R, Y, Z, AA, BB, MM, PP, QQ) Second Floor Area 1 — Shredder Staging Lower Level Area 1 — Staging Area 2 — Staging Total Building 145 Building 77 Dock Stalls Drum Storage Building 136 (Tanker Unloading Building) Dock Stalls Drum Storage Total Waste Volume (All Buildings: 47, 60,145, 77 and 136) MAXIMUM STORAGE CAPACITY (Drums)* 4 408 60 12 2 1,038 176 drums or 2 tankers 76 176 drums or 2 tankers Z 3,640 drums -or- 3,288 drums and 4 tankers MAXIMUM STORAGE CAPACITY (Gallons) 200 20,400 3,000 600 100 51,900 8,800 or 13,000 3,800 8,800 (drums) or 13,000 (tankers) 3,800 182,000 (drums) or 190,400 (drums and tankers) SECONDARY CONTAINMENT VOLUME (Gallons) 330 4,807 1,450 1,270 590 8,110 23,260 Total Waste Volume 50,280 drums 2,514,000 (drums) (All Buildings and Trailers) -or- or 2,719,800 41,656 drums and (drums and 98 tankers tankers) * Number in parentheses are the number of drums containing free liquid that may be stored in the area. 8 of 67 EPA ID # MND006172969 April 2012 D. STORAGE OF HAZARDOUS WASTE IN TANKS The Permittee is authorized to store hazardous wastes having the waste codes specified in Appendix II of the Permit in tanks as specified in the following table: Approved Hazardous Waste Tanks Storage LOCATION APPROVED TANK MAXIMUM STORAGE CAPACITY Gallons SECONDARY CONTAINMENT VOLUME (Gallons) Hazardous Waste Tank Farm Decant Tank #20 10,000 38,930 Tank #21 18,360 46,850 Tank #22 18,360 46,850 Tank #23 18,360 46,850 Tank #24 18,360 46,850 Tank #25 18,360 46,850 Tank #26 18,360 46,850 Tank #27 18,360 46,850 Tank #28 1 18,360 1 46,850 Tank #1 1 200,000 1 228,000 E. MISCELLANEOUS UNIT The Permittee is authorized to process hazardous wastes in the Komar shredder and is also authorized to decontaminate and rinse equipment and parts in the Decontamination Area. F. CONTAINMENT BUILDING This Permittee is authorized to store ash and slag generated by the incineration process in Containment Building 181. Ash and slag are stored here prior to shipment off site for hazardous waste landfill disposal. This building may also be used to store bulk solids and contaminated soils prior to incineration. Requirements for storage in containment buildings are contained in Part III.A.6. of this Permit. G. TREATMENT OF HAZARDOUS WASTE IN INCINERATOR 1. This Permit authorizes operation of the hazardous waste incinerator, subject to the requirements of this Permit and the conditions in the Title V Air Emission Facility Permit No. 16300025 -002 issued by the MPCA on (effective date of Air Permit). 2. This Permit enables the Permittee to meet the requirements of Minn. R. 7001.0520, subps. I .A. and I.B. to obtain a hazardous waste facility permit for treatment of hazardous waste and for operation of the incinerator. 9 of 67 EPA ID # MND006172969 April 2012 PART III. OPERATING CONDITIONS A. OPERATION AND MAINTENANCE 1. General a. The Permittee shall at all times properly operate and maintain the hazardous waste storage and treatment Facility, including all hazardous waste management units and all appurtenances related to the storage and treatment of hazardous wastes. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls. The Permittee shall install and maintain appropriate back -up and auxiliary facilities as needed to remain in compliance with the terms and conditions of this Permit. b. The Permittee shall prevent the discharge of hazardous waste from the Facility to the surface waters or groundwaters of the State. The Permittee shall prevent hazardous waste from entering drains, sewer inlets, storm sewers, sanitary sewers, doorways, vents, tunnels, pipes, windows, and other areas with permeable floors. C. The Permittee shall operate and maintain the Facility to minimize the possibility of fire, explosion, or other event that might allow hazardous wastes to escape into the air, land, or water. 2. Containers a. Condition of Containers The Permittee must ensure that the type and condition of containers used to store hazardous waste are selected and maintained in accordance with Minn. R. 7045.0526. 1) The containers must be of sturdy leak -proof construction, adequate wall thickness, adequate weld, hinge, and seam strength. Further, they must be of sufficient strength to withstand side and bottom shock, when filled, without impairment of the ability of the container to fully contain the hazardous waste; and 2) The containers must have lids, caps, hinges, or other closure devices of sufficient strength and construction so that when closed they will withstand dropping, overturning, or other shock without impairment of the container's ability to fully contain the hazardous waste. 3) The containers must be made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored and other substances that the container may predictably contact, so that the ability of the container to contain the waste is not impaired. 10 of 67 EPA ID # MND006172969 April 2012 4) If a container holding hazardous waste does not meet the above requirements, or if it begins to leak, the Permittee shall transfer the hazardous waste in the defective container to a container that does meet the above requirements, or manage the waste in some other way that complies with the requirements of Minn. R 7045.0526. b. Management of Containers 1) A container holding hazardous waste must be labeled and include the words "Hazardous Waste ", a content description, and with the exception of containers being used for satellite accumulation, the accumulation start date. Containers must be kept closed during storage, except when it is necessary to add or remove waste. 2) A container holding hazardous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak. 3) Containers "in process," meaning those containers that have been inspected and staged for treatment, may be provided with temporary covers to minimize air emissions. If waste feeds to the incinerator are expected to be halted for longer than 24 hours, in- process containers must be fitted with a lid as described in item A.2.a.2) above. 4) Containers containing controlled substance waste from Minnesota law enforcement agencies shall be burned upon receipt at the incinerator and shall not be stored at the Facility. If 3M cannot burn the controlled substance wastes upon receipt, the containers shall not be accepted by 3M and shall remain in possession of the law enforcement agency. C. Container Secondary Containment. 1) Buildings The Permittee shall maintain the container storage area secondary containment systems within Facility buildings to ensure that the system is capable of collecting and holding spills and leaks. The maintenance of the secondary containment system must ensure that: a) The compatible base underlying the containers is free of cracks or gaps (in the concrete or in the sealer) and is sufficiently impervious so as to contain leaks and spills until the collected material is detected and removed. b) The compatible base is sloped to contain or drain and remove liquid resulting from leaks, spills, and accumulated precipitation. c) The secondary containment system has sufficient capacity to contain at least ten percent of the volume of all containers in the secondary containment or the volume of the largest container in the secondary containment, whichever is greater. Containers that do not contain free liquids need not be considered in this determination; however, containers that do not contain free liquids must be clearly labeled or easily identified (e.g., boxes of lamps). 11 of 67 EPA ID # MND006172969 April 2012 d) The interface between the dike or sidewall and the underlying base of the container storage area secondary containment system is sealed to contain leaks, spills, and accumulated liquids. 2) Trailers The Permittee shall maintain the secondary containment system for each trailer used to store containerized hazardous waste to ensure that each system is capable of collecting and holding spills or leaks. The trailer secondary container systems may consist of containment liners constructed of plate steel, containment pallets, or coated concrete secondary containment. When using steel containment liners, the maintenance of the trailer secondary containment systems must ensure that: a) The steel containment liners remain free of holes, cracks, corrosion or deformations that compromise the integrity and imperviousness of the containment system. b) When storing liquid hazardous waste, the base of the liner is sloped downward toward the front of the trailer to maintain the required volume of secondary containment. The required slopes shall be recorded in the operating log. Containers stored in trailers must be stored on pallets or be provided with other means to be separated from leaks, spills or precipitation. For waste that is spilled or leaked the Permittee shall comply with Minn. R. 7045.0526, subp. 6.C. 3. Tanks The Permittee shall operate all tank systems (each tank, ancillary equipment and secondary containment system) in accordance with Minn. R. 7045.0528 and this part of this Permit. Written tank assessments required by Minn. R. 7045.0528, subps. 2 and 3 must be maintained at the Facility. a. Tank Secondary Containment and Detection of Releases. Secondary containment for all tanks, except for Tank # 1, is provided by concrete containment basins. The secondary containment system for Tank #1 is the outer steel shell and a double- bottom. All of these secondary containment systems must be operated to prevent the migration of hazardous waste or constituents or accumulated liquid to the soil, ground water or surface water, as well as to detect and collect releases and accumulated liquid until the collected material is removed. Specifically, the secondary containment systems must be: 1) Constructed of or lined with materials that are maintained to be compatible with the hazardous waste placed in tanks and must have sufficient strength and thickness to prevent failure because of pressure gradients, including static head and external hydrological forces, physical contact with the waste to which it is exposed, climatic conditions and the stress of daily operation, including stresses from nearby vehicular traffic. 2) Placed on a foundation or base capable of providing support to the secondary containment system, resistant to pressure gradients above and below the system, and capable of preventing failure due to settlement, compression or uplift. 12 of 67 EPA ID # MND006172969 April 2012 3) Provided with a leak detection system that is designed and operated to detect the failure of either the primary or secondary containment structure or the release of any hazardous waste or accumulated liquid in the secondary containment system WITHIN 24 HOURS. 4) Sloped or otherwise designed or operated to drain and remove liquids resulting from leaks, spills and precipitation. b. General Tank Operating Requirements 1) In addition to the requirements of A.3.a. of this Section, the Permittee shall maintain the applicable diked coated concrete external liner secondary containment system and the Tank #1 secondary containment system in accordance with Minn. R. 7045.0528, subp. 4, item E. 2) The Permittee shall maintain secondary containment for tank ancillary equipment in accordance with Minn. R. 7045.0528, subp. 4, item H. 3) Valves, pipes, fittings and other closure devices and appurtenances must be of sufficient strength to withstand shock and internal pressure without impairment of the ability of the tank to fully contain the waste. Gasketed closures must be fitted with gaskets comprised of materials that are sufficient to prevent leakage and that will not be deteriorated by the contents. 4) For spill prevention controls the Permittee shall use lockable couplings such as cam and groove, in conjunction with a system to allow the draining of the hose between the tanker and the first permanent process unloading valve. The hose and associated piping must be drained prior to uncoupling the hose from the tankers. Further, high level alarms, automatic feed cutoffs and /or overflow lines shall be used as overfill prevention devices. These controls and devices shall be properly operated and maintained to prevent failure of the tank system. 4. Miscellaneous Units The Permittee shall operate the Komar shredder and the Decontamination Area in accordance with Minn. R. 7045.0539 and this part of the Permit. The Komar shredder and the Decontamination Area must be operated, maintained, and closed in a manner that will ensure protection of human health and the environment. Protection of human health and the environment includes, but is not limited to prevention of any releases that may have an adverse effect on human health or the environment due to migration of waste constituents: (1) In the ground water or subsurface environment. (2) In surface water, or wetlands or on the soil surface. (3) In the air. 13 of 67 EPA ID # MND006172969 April 2012 a. In order to minimize fugitive emissions, the Permittee shall operate the Komar shredder such that: 1) At least one set of doors of the pallet chamber is closed at all times when the Komar shredder is operating, and 2) Purged gases from the pallet chamber are vented to the incinerator kiln at all times when the Komar shredder is operating. All vents from the Komar shredder must be vented to the rotary kiln combustion system through a closed -vent system, as herein specified, for destruction of volatile organic compounds. The closed -vent system shall be operated according to Minn. R. 7045.0551. b. The Permittee shall perform preventative maintenance on the Komar shredder to insure the seals of the pallet chamber doors are in good working order. C. The Permittee shall inspect the blow -out panels on the Komar shredder in accordance with the following requirements. 1) The blow -out panels shall be visually inspected by the Permittee to check for defects that could result in air pollutant emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in the blow -out panels, or between the blow -out panels and their frames; broken, cracked, or otherwise damaged seals or gaskets; and broken or missing blow -out panels or frames. 2) The Permittee shall perform an inspection of the blowout panels at least annually. 3) In the event that a defect is detected, the Permittee shall repair the defect in accordance with the following requirements: The Permittee shall make first efforts at repair of the defect no later than 5 calendar days after detection, and repair shall be completed as soon as possible but no later than 45 calendar days after detection of the defect. 4) The Permittee shall maintain a record of the inspections and repairs in the Operating Record in accordance with the requirements specified in Part V.13.6. of this Permit. d. The Permittee shall inspect the Komar shredder daily for liquid waste leaks, and shall clean up and contain such leaks immediately. 1) In the event that a leak is detected, the Permittee shall repair the leak in accordance with the following requirements: The Permittee shall make first efforts at repair of the leak no later than 5 calendar days after detection, and repair shall be completed as soon as possible but no later than 45 calendar days after detection of the leak. 14 of 67 EPA ID # MND006172969 April 2012 2) The Permittee shall maintain a record of the inspections and repairs in the Operating Record in accordance with the requirements specified in Part V.B.6. of this Permit. No reactive hazardous waste (D003) shall be shredded in the Komar shredder. f. No containers shall be shredded in the Komar shredder unless the oxygen monitoring system in the shredding chamber is operational and indicating that the oxygen concentration is within the proper range or unless an equivalent safety system is provided. Palletized containers and a single drum must be fed through the pallet pre- chamber airlock and the single drum pre- chamber airlock respectively. The single drum pre- chamber airlock, pallet pre- chamber airlock, and the drop chamber must be purged with nitrogen and equipped with carbon dioxide fire extinguishing system to prevent fire or explosions. g. No containers shall be shredded in the Komar shredder following an event in which unit over - pressure results in the use of the shredder emergency stack, until an incident investigation of the cause of the over - pressure has been completed by the Permittee. h. The infeed system of the Komar shredder consists of: 1) Two infeed staging conveyors 2) A pallet pre- chamber /airlock 3) A single drum pre- chamber airlock The airlock chamber and the prechamber must be equipped with integral gas -tight doors, a gas sampling system, inert gas (nitrogen) controls and a temperature sensor assembly for fire suppression. The drop chamber must be equipped with a gas sampling system, nitrogen blanketing, and temperature sensor. i. The drop chamber of the Komar shredder must be equipped with an expansion relief door panels (i.e., explosion/rupture disc). Permittee must investigate the cause of any release and report the incident in accordance with Part IV.G of this permit. After any release, the expansion relief door panel must be repaired and tested to ensure that it is gas- tight. j. The oxygen monitoring and sampling system must be capable of monitoring and maintaining an oxygen concentration of less than 5 % when the Komar shredder is in operations. k. A primary carbon dioxide fire suppression system on the Komar shredder must be activated when the chamber temperature reaches 190 °F and the backup light water system is activated at 300 °F. 1. The expansion relief door panels on the Komar shredder must be ruptured when the drop chamber pressure reaches 5 psi at 72 °F ambient temperature. The condition of the expansion relief door panels must be monitored continuously for the condition of the door panels. 15 of 67 EPA ID # MND006172969 April 2012 m. In order to minimize fugitive emissions from the Decontamination Area, the Permittee shall erect a temporary screen or enclosure whenever there is the potential for material to become windborne during decontamination activities. n. All liquids will be removed from the sump in the Decontamination Area on a daily basis. o. Any equipment or material placed in the Decontamination Area, or generated from decontamination activities, shall be removed from the Decontamination Area within 24 hours. 5. Incinerator Comply with the Performance Standards, Operating Conditions, and Performance Test Requirements listed in Part XIII of this Permit. In order to limit the risk to human health and the environment, the Permittee shall not burn in the incinerator any wastes which: a. Are radioactive wastes, as defined in the Atomic Energy Act, or b. Contain polychlorinated biphenyls (PCBs) at a concentration of 50 parts per million or greater. 6. Containment Building As provided in Part II.F. of this Permit, the Permittee is authorized to store ash and slag generated by the incineration process in Containment Building 181 (hereinafter "containment building" or "unit ") prior to shipment offsite for hazardous waste landfill disposal. This building may also be used to store bulk solids and contaminated soil prior to incineration. a. Incompatible hazardous wastes or treatment reagents shall not be placed in the unit or its secondary containment system if they could cause the unit or secondary containment system to leak, corrode, or otherwise fail. All surfaces to be in contact with hazardous wastes must be chemically compatible with those wastes. The containment building shall have a primary barrier designed to withstand the movement of personnel, waste, and handling equipment in the unit during the operating life of the unit and appropriate for the physical and chemical characteristics of the waste to be managed. b. The containment building shall include: 1) A primary barrier designed and constructed of materials to prevent the migration of hazardous waste or hazardous constituents into the barrier. 2) A liquid collection and removal system to minimize the accumulation of liquid on the primary barrier of the containment building: 16 of 67 EPA ID # MND006172969 April 2012 a) The primary barrier shall be sloped to drain liquids to the associated collection system; and b) Liquids and waste shall be collected and removed to minimize hydraulic head on the containment system at the earliest practicable time. If water is present, it shall be collected and removed from the floor of the building a minimum of once per day, or more often during the day whenever the quantity of free liquids is estimated to be greater than 31 gallons, for subsequent treatment and disposal. 3) A secondary containment system including a secondary barrier designed and constructed to prevent migration of hazardous waste or hazardous constituents into the barrier, and a leak detection system that is capable of detecting failure of the primary barrier and collecting accumulated hazardous wastes and liquids at the earliest practicable time. C. Permittee shall ensure that operation of the containment building complies with the following: 1) Use controls and practices to ensure containment of the hazardous waste within the unit; which must include, at a minimum, the following: a) The concrete floor in the containment building shall be treated annually with a chemically compatible sealant. The floor shall be regularly inspected for evidence of significant cracks, gaps, corrosion or other deterioration that could cause hazardous waste to be released from the primary barrier. The following inspections shall be conducted: (1) Visual inspection of the visible floor area daily (2) Visual inspection of the floor area after ash is removed for shipment. (3) Cleaning and inspection of the entire floor of the building semiannually. If the Permittee discovers degradation of the primary barrier that could cause hazardous waste to be released from the primary barrier, the Permittee shall complete appropriate repairs as soon as practicable. b) Maintain the level of the stored /treated hazardous waste within the containment walls of the unit so that the height of any containment wall is not exceeded; c) Take measures to prevent the tracking of hazardous waste out of the unit by personnel or by equipment used in handling the waste. An area must be designated to decontaminate equipment and any rinsate must be collected and properly managed; and 17 of 67 EPA ID # MND006172969 April 2012 d) Take measures to control fugitive dust emissions such that any openings (doors, windows, vents, cracks, etc.) exhibit no visible emissions. In addition, all associated particulate collection devices (e.g., fabric filter, electrostatic precipitator) must be operated and maintained with sound air pollution control practices. This state of no visible emissions must be maintained effectively at all times during routine operating and maintenance conditions, including when vehicles and personnel are entering and exiting the unit. 2) Obtain and keep on -site a certification by a qualified Professional Engineer that the containment building design meets the requirements of paragraphs a, b, and c of this section. 3) Throughout the active life of the containment building, if the Permittee detects a condition that could lead to or has caused a release of hazardous waste, the Permittee must repair the condition promptly, in accordance with the following procedures. a) Upon detection of a condition that has led to a release of hazardous waste (e.g., upon detection of leakage from the primary barrier) the Permittee must: (1) Enter a record of the discovery in the Facility operating record; (2) Immediately remove the portion of the containment building affected by the condition from service; (3) Determine what steps must be taken to repair the containment building, remove any leakage from the secondary collection system, and establish a schedule for accomplishing the cleanup and repairs; and (4) Within 7 days after the discovery of the condition, notify the Commissioner of the condition, and within 14 working days, provide a written notice to the Commissioner with a plan containing a description of the steps that will be taken to repair the containment building, and the schedule for accomplishing the work. b) The Commissioner will review the information submitted, make a determination regarding whether the containment building must be removed from service completely or partially until repairs and cleanup are complete, and notify the Permittee of the determination and the underlying rationale in writing. c) Upon completing all repairs and cleanup the Permittee must notify the Commissioner in writing and provide a verification, signed by a qualified, registered professional engineer, that the repairs and cleanup have been completed according to the written plan submitted in accordance with paragraph c.3)a)(4) of this section. 18 of 67 EPA ID # MND006172969 April 2012 4) Inspect and record in the Facility's operating record, at least once every seven days data gathered from monitoring and leak detection equipment and inspections of the containment building and the area immediately surrounding the containment building to detect signs of releases of hazardous waste. d. Closure and post - closure care. 1) At closure of the containment building, the Permittee must remove or decontaminate all waste residues, contaminated containment system components (liners, etc.) contaminated subsoils, and structures and equipment contaminated with waste or leachate, and manage them in accordance with MPCA hazardous waste requirements. The closure plan and closure activities for the containment building must meet all of the closure requirements in 40 CFR pt. 264, subp. G. The cost estimates for closure and the financial assurance requirements for containment buildings must meet the financial assurance requirements in Minn. R. 7045.0498 to 7045.0524. 2) If, after removing or decontaminating all residues and making all reasonable efforts to effect removal or decontamination of contaminated components, subsoils, structures, and equipment as required in paragraph d. 1) above, the Permittee finds that not all contaminated subsoils can be practicably removed or decontaminated, the Permittee must close the containment building and perform post - closure care in accordance with the closure and post - closure requirements that apply to landfills in Minn. R. 7045.0538. In addition, for the purposes of closure, post - closure, and financial assurance, the containment building is then considered to be a landfill, and the Permittee must meet all of the requirements for landfills specified in Minn. R. 7045.0538 and the financial assurance requirements in Minn. R. 7045.0498- .0524. B. NOTICE TO GENERATORS In accordance with Minn. R. 7045.0452, subp. 3, item C, the Permittee shall notify and document in writing to each non -3M generator from whom it receives wastes that the Permittee has received this Permit and will accept the waste. The Permittee shall also follow the Waste and Feedstream Analysis Plan in Section C of the Permit Application. The Permittee shall also develop and distribute procedures to generators of non -3M wastes that outline the requirements for acceptance and disposal of their wastes at the Facility. C. RECEIPT OF UNAUTHORIZED WASTES In the event the Permittee receives a shipment of hazardous wastes that the Permittee is not authorized to receive and store at the Facility, the Permittee shall reject the waste or, IMMEDIATELY notify the MPCA and wait for further instructions before accepting the waste. This is required by Minn. R. 7045.0452, subp. 3, item B. 19 of 67 EPA ID # MND006172969 April 2012 D. RESERVED E. GENERAL WASTE ANALYSIS To comply with the waste analysis requirements in Minn. R. 7045.0458, 7045.0456, 7045.0542, 7045.1390, and 7001.0560, the Permittee shall follow the procedures described in the Corporate Incinerator Waste and Feedstream Analysis Plans (WAP/FAP) found in Section C of the Permit Application. The WAP/FAP in the Permit Application is an integral part of this Permit and includes requirements and procedures for waste stream pre- acceptance procedures, incoming waste inspection procedures, laboratory analysis performed prior to incineration, waste stream profile verification, compliance demonstration methods, analysis parameters and rationale, waste analysis test methods, waste sampling methods, off -site waste analysis, waste tracking system, additional waste analysis requirements, quality control and recordkeeping. F. PERSONNEL TRAINING The Permittee shall not allow any employee to work at the Facility in a job related to hazardous waste management until that employee has received all training required by Minn. R. 7045.0454 and the current Personnel Training Program set forth in Vol. 1, Section K of the Permit Application. The Permittee shall update the Personnel Training Program whenever there is a significant change in Facility operations or regulatory requirements. The Permittee shall maintain a copy of the Personnel Training Program at the Facility in its Facility records. G. HANDLING MANIFESTS The Permittee shall comply with the manifest requirements in Minn. R. 7045.0474. H. MANIFEST DISCREPANCIES 1. If the Permittee discovers a major discrepancy in a manifest, the Permittee shall attempt to reconcile the discrepancy. If the Permittee is unable to reconcile the discrepancy with the generator and transporter WITHIN TEN (10) DAYS, the Permittee shall IMMEDIATELY submit to the MPCA a letter describing the discrepancy, attempts made to reconcile it, and a copy of the manifest or shipping paper. The type of discrepancy must be noted on the manifest. 2. If the Permittee discovers a minor discrepancy in a manifest, the Permittee shall attempt to reconcile the discrepancy with the generator and transporter. If the discrepancy cannot be reconciled, the Permittee shall note the type of discrepancy and its resolution on the manifest. 3. The definitions of "major discrepancy" and "minor discrepancy" can be found in Minn. R. 7045.0476, subp. 2. 20 of 67 EPA ID # MND006172969 April 2012 I. MONITORING In the event the Permittee shall be required by the MPCA to conduct monitoring, the Permittee shall follow the requirements of an MPCA approved monitoring plan. J. STORAGE OF IGNITABLE, REACTIVE, AND INCOMPATIBLE WASTES 1. General Requirements a. Required notices The Permittee shall take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction, including, but not limited to open flames, smoking, cutting and welding, hot surfaces, frictional heat, static sparks, electrical sparks, mechanical sparks, spontaneous ignition, and radiant heat. The Permittee shall post a sign legible from a distance of 25 feet with the legend, "No Smoking" at each entrance to the Facility. The Permittee shall comply with the requirements of Minn. R. 7045.0456 and the procedures provided in Vol.l Section I of the Permit Application. b. Required precautions As specifically required by Minn. R. 7045.0456, subp. 2, the Permittee of a Facility that treats, stores, or disposes of ignitable or reactive waste or that mixes incompatible wastes or incompatible wastes and other materials, shall take precautions to prevent reactions which: 1) Generate extreme heat, pressure, fire, explosions, or violent reactions unless the Permittee is Permitted to handle these types of reactions; 2) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health or the environment; 3) Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions; 4) Damage the structural integrity of the device or Facility; or 5) Through other means threaten human health or the environment. 2. Special Requirements for Ignitable and Reactive Wastes a. Storage in containers Containers holding ignitable or reactive wastes and materials must be located at least 15 meters (50 feet) from the Facility's property line as delineated on the map in Volume 2, Appendix Tab A of the Permit Application. b. Storage in tanks Ignitable and reactive wastes placed in tanks must be stored in such a way that they are protected from any materials or conditions which may cause the waste to ignite or react. Protective distances must be followed as specified in the Uniform Fire Code. 21 of 67 EPA ID # MND006172969 April 2012 3. Special Requirements for Incompatible Wastes a. Storaize in containers 1) Incompatible wastes or wastes which are incompatible with other material must not be placed in the same container, unless compliance with Minn. R. 7045.0456, subp. 2, is achieved. 2) Hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material unless the waste is in a sealed container within the container. As required by Minn. R. 7045.0458, subp. 2, the Waste Analysis Plan must include analyses to comply with these special requirements. Minn. R. 7045.0456, subp. 3, requires waste analyses, trial tests, and documentation to ensure compliance with Minn. R. 7045.0456, subp. 2. All results obtained from testing must be maintained in the Facility operating record. 3) A storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, waste piles, open tanks, or surface impoundments, must be separated from other such waste or material by means of a dike, berm, wall, or other protective device. b. Storage in Tanks Incompatible wastes and /or incompatible wastes and materials must not be placed in the same tank, unless compliance with Part III.J.I .b. above is maintained. K. INSPECTIONS The Permittee shall conduct inspections at the Facility and of all hazardous waste management units at the Facility in accordance with the Inspection Section in Vol. 1, Section E of the Permit Application. The inspections shall also be in accordance with the requirements in Minn. R. 7045.0452, subp. 5, items A -E (general inspection requirements), 7045.0526, subp. 5 (containers), and 7045.0528, subp. 7 (tanks). Record of inspections shall be maintained in accordance with Part V (Record Keeping Requirements) of this Permit and according with Volume 1, Section E.6. of the Permit Application. 22 of 67 EPA ID # MND006172969 April 2012 L. SECURITY In accordance with Minn. R. 7045.0452, subp. 4, the Permittee shall maintain a 24 -hour surveillance system which continuously monitors and controls entry onto the active portion of the Facility, or an artificial or natural barrier which completely surrounds the active portion of the Facility and a means to control entry at all times through gates or other entrances to the active portion of the Facility. The fence shall be locked at times when the Facility is unattended and access to the Facility shall be provided only to persons who are authorized by the Permittee to enter the Facility. The Permittee shall post a sign legible from a distance of 25 feet with the legend, "Danger - Unauthorized Personnel Keep Out," at each entrance to the Facility as defined in Minn. R. 7045.0020, subp. 3. The Facility provides several security measures such as fencing, security guards, controlled entry, and a surveillance system. The incinerator portion of the Facility is enclosed with a second security fence and has its own surveillance system, building access control, security patrols, and warnings signs. M. LIGHTING The Permittee shall provide adequate lighting for the Facility to ensure safety and proper operation. N. FINANCIAL ASSURANCE FOR CLOSURE The Permittee shall provide a Financial Test and Corporate Guarantee in the amount of the cost estimated to close the Facility, in accordance with the financial assurance requirements of Minn. R. 7045.0504, subp. 7. The Permittee shall continue to maintain such a Financial Test and Corporate Guarantee unless the MPCA approves of the use of another mechanism as specified in Minn. R. 7045.0504. The Permittee shall certify that 3M meets the Financial Test and Corporate Guarantee for closure by March 31 of each year. O. LIABILITY COVERAGE The Permittee shall have and maintain liability coverage for sudden accidental occurrences in the amount of at least One Million Dollars ($1,000,000) per occurrence, with an annual aggregate coverage in the amount of at least Two Million Dollars ($2,000,000), exclusive of legal defense costs in accordance with the requirements of Minn. R. 7045.0518. The Permittee shall comply with this requirement through the use of Financial Test for Liability Coverage under Minn. R. 7045.0518, subp. 6. The Permittee shall continue to maintain such a Financial Test for Liability Coverage unless the MPCA approves of the use of another mechanism as specified in Minn. R. 7045.0518. 23 of 67 EPA ID # MND006172969 April 2012 P. WASTE PROCESSING 1. Shipments of hazardous waste may be staged in Lot C or the south, paved half of Lot A for no longer than 10 days prior to receiving in Buildings 47 or 60 as described in the Permit Application, Vol. 1, Section A.3.1 "Containerized Materials Receiving, Storage, and Handling." 2. Except as provided in Part III.P.1. of this Permit, the Permittee shall place hazardous waste from off -site generators into permitted storage areas within 24 hours after arrival of the waste at the Facility. 3. In receiving and handling hazardous wastes at the Facility, the Permittee shall follow the requirements in this Permit and the procedures in Vol. 1, Section A.3. of the Permit Application. Q. RESERVED R. SPECIAL CONDITIONS FOR EXISTING UNITS 3M conducted a screening level Human Health Risk Assessment (HPRA) for the incinerator in 2004 (2004 HHRA). The 2004 HHRA concluded that the routine emissions from the incinerator were not expected to present significant risks to the public. In 2005, EPA updated its HHRA guidance to include, among other changes, dry gas deposition of mercury as a separate dispersion modeling pathway. In light of the updated HHRA guidance, the MPCA is requiring that 3M update the 2004 HHIZA. 3M shall submit to the MPCA a work plan to update the 2004 HHRA to include the dry gas deposition of mercury pathway and to address other changes to the HHRA guidance and facility - specific conditions. The work plan shall include the air - modeling and risk assessment protocol and a proposed schedule for completion of the HHRA. The work plan shall be submitted to the MPCA for review and approval within 90 days after the effective date of this Permit. The updated HHRA shall characterize any potential adverse impacts to human health based on actual operating scenarios that may occur under the terms of the permit. Components of the updated HHRA shall include air dispersion /deposition modeling, fate and transport modeling, trial burn results (as applicable), meteorological data, hazard identification, dose - response evaluation, site - specific multi - pathway analysis to evaluate direct and indirect exposure, and risk characterization. The updated HHRA shall be subject to MPCA review and approval, with EPA's consultation, and shall be conducted in accordance with the most recent EPA HHRA guidance, rules, and requirements in effect at the time of performance and shall also include at least the following: 24 of 67 EPA ID # MND006172969 April 2012 1. Summary of existing health risk assessment data. 2. Summary of current EPA HHRA guidance. 3. Identification of additional data required to meet current HHRA guidance. The Permittee shall use the most current guidance and models at the time the updated HHRA is conducted. The most recent guidance at the time of permit issuance for conducting a human health risk assessment for combustion sources is: Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities, Office of Solid Waste and Emergency Response, U.S. EPA, EPA530 -R -05 -006, September 2005. In selecting an appropriate air dispersion model, the Permittee shall consider the models for dispersion of stack gasses specified in Appendix A to Appendix W of 40 CFR Part 51, including AERMOD. In selecting an appropriate method for processing meteorological data for use in dispersion models, the Permittee shall consider the following draft guidance document: DRAFT - For Discussion Purposes - Regional Meteorological Data Processing Protocol, U.S. EPA Region 5 and States, May 6, 2011. The HHRA work plan will be reviewed by MPCA in accordance with Part X of this Permit (Review of Submittals and Extension of Schedules) and in consultation with EPA. Upon approval of the HHRA work plan, 3M shall conduct the revised HHRA and submit a report documenting the revised HHRA and results in accordance with the schedule in the approved HHRA work plan. If an updated HHRA shows that potential unacceptable human health risks exist due to emissions from the 3M corporate incinerator, the Commissioner will modify the Permit to address the risk. The Permit modification will be in accordance with the requirements of Part IX.P of this Permit (Modification, Revocation, and Reissuance of this Permit) and the procedures in Minn. R. 7001.0190 and 7001.0730 and 7001.0100 to 7001.0130. 25 of 67 EPA ID # MND006172969 April 2012 PART IV. EMERGENCY PROCEDURES A. IMPLEMENTATION OF CONTINGENCY PLAN In accordance with Minn. R. 7045.0466, subp. 3, the Permittee must ensure that the provisions of the Contingency Plan, set forth in Vol. 1 Section G of the Permit Application, are carried out IMMEDIATELY whenever there is a release, fire, or explosion of hazardous waste or hazardous constituents which could threaten human health or the environment. B. AMENDMENT OF CONTINGENCY PLAN 1. The Permittee shall amend the contingency plan whenever: a. This Permit is revised, b. Said plan fails in an emergency, C. The Facility changes in its design, construction, operation, maintenance, or other circumstance in a way that increases the potential for fires, explosions, or the release of hazardous waste or hazardous constituents, or changes the response necessary in an emergency, d. The designated emergency coordinator changes, or The list of emergency equipment changes. 2. The Permittee shall maintain a copy of its contingency plan at the Facility at all times. 3. The Permittee shall submit a copy of its contingency plan to all local police departments, fire departments, hospitals, and all local and state emergency response teams that may be called upon to respond in an emergency situation at the Facility. C. PREPAREDNESS AND PREVENTION The Permittee shall follow the procedures set forth in Vol. 1, Sections F and H of the Permit Application. 1. Required equipment At a minimum, the Permittee shall maintain emergency equipment required by the Contingency Plan. 2. Testing and maintenance of equipment The Permittee shall test and maintain all Facility communications or alarm systems, fire protection equipment, and spill control equipment to ensure proper operation in time of emergency. The maintenance and inspection of emergency equipment shall be conducted in accordance with the Inspection Plan set forth in Vol. 1, Section E of the Permit Application. 26 of 67 EPA ID # MND006172969 April 2012 3. Access to communications or alarm system The Permittee shall ensure that whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation shall have immediate access to an internal alarm or emergency communication device, either directly or through visual and /or voice contact with another employee. 4. Aisle space The Permittee shall maintain aisle space in all hazardous waste storage and treatment areas to allow the unobstructed movement in an emergency of personnel, fire protection equipment, spill control equipment, and decontamination equipment. This requirement does not apply to trailer storage in Lots C or the south half of Lot A for up to ten days after the trailers have arrived at the Facility prior to official receipt of the trailer. 5. Preparedness and Prevention Procedures The Permittee shall follow the preparedness and prevention procedures set forth in Vol. 1, Sections F and H of the Permit Application. D. EMERGENCY COORDINATOR In accordance with Minn. R. 7045.0468, subp. 1, the Permittee shall at all times have at least one (1) employee either on the Facility premises or on call with the responsibility for coordinating all emergency response measures. The following employees have been designated as the Emergency Coordinators in the Contingency Plan. PLANT EMERGENCY COORDINATORS The Permittee may change the names of employees who qualify as emergency coordinator by contacting the MPCA and identifying the new emergency coordinator(s). The Permittee shall also amend its Contingency Plan whenever new emergency coordinators are designated. 27 of 67 EPA ID # MND006172969 April 2012 CELL PHONES/ NAME WORK HOME PHONE PAGER HOME ADDRESS PHONE Craig Mara 651- 768 -1565 715- 381 -0049 651- 295 -7506 - 2249 Ruby Road Cell Hudson, WI 54016 Scott Johnson 651- 458 -2314 715- 665 -9224 651- 373 -2371 — N7177 80 Street Cell Knapp, WI 54749 Steve Kosch 651- 768 -1545 715- 698 -3542 651- 207 -2755 — 2684 County Road D Cell Woodville, WI 54028 Gary Garner 651- 458 -1430 651 -552 -0696 651 -592 -4763 — 816 Park Place Drive Cell Mendota Heights, MN 55118 The Permittee may change the names of employees who qualify as emergency coordinator by contacting the MPCA and identifying the new emergency coordinator(s). The Permittee shall also amend its Contingency Plan whenever new emergency coordinators are designated. 27 of 67 EPA ID # MND006172969 April 2012 E. RESPONSE TO SPILLS/LEAKS/RELEASES FROM REGULATED UNITS 1. Tanks If there should be a leak of hazardous waste from the "tank system" (which is defined to include the tank, secondary containment system, and all ancillary equipment such as pumps, valves, monitoring equipment etc.), the Permittee shall comply with the following requirements: a. IMMEDIATELY stop the flow of hazardous waste into the tank system and inspect the tank system to determine the cause of the leak. b. WITHIN 24 HOURS after detection of the leak, or at the earliest practicable time, whichever is sooner, remove as much of the waste as is necessary to prevent further release of hazardous waste to the environment (i.e., escaping the secondary containment system) and repair the tank system. C. IMMEDIATELY conduct a visual inspection of all property affected by the release. Based upon the inspection findings, the Permittee shall prevent further migration of the release to surrounding soils and surface waters. All contaminated media, structures, and equipment shall be properly managed at the direction of the MPCA. d. The Permittee must notify the MPCA IMMEDIATELY after a release of hazardous waste to the environment if it is determined, based on the criteria in Part IV.G. of this Permit, that such notification is required. e. The Permittee shall evaluate the release and submit a written report to the MPCA WITHIN 15 DAYS after detection of a release requiring implementation of the contingency plan. This report must contain the following information and may be combined with the report required in Part IV.L of this Permit. 1) The likely route of migration of the release. 2) The characteristics of the surrounding soil, including soil composition, geology, hydrogeology, and climate. 3) The results of any monitoring or sampling conducted in connection with the release, if available. If sampling or monitoring is not available WITHIN 15 DAYS after detection of the release, the data must be submitted to the MPCA as soon as they become available. 4) The proximity to downgradient drinking water, surface water, and populated areas. 5) A description of response actions taken or planned. 28 of 67 EPA ID # MND006172969 April 2012 f. The Permittee need not submit the written report required under item e. above if the release from the tank system involved less than one (1) pound of hazardous waste and the Permittee IMMEDIATELY contained and cleaned up the released wastes or if the release was entirely contained within the secondary containment system. The Permittee shall keep a record in its operating records of the date of and information about the release, including the hazardous waste released, the quantity of the release, cleanup measures taken, and how the released material was managed. The Permittee shall also report the release in its annual report submitted under Part VI.C.1. g. In addition to the requirements in items a. through e. above, the Permittee shall follow the procedures specified in Part IV, hereof (Emergency Procedures) if the leak should cause an emergency situation requiring implementation of the contingency plan. h. The Permittee shall repair the tank secondary containment system in accordance with Minn. R. 7045.0528, subp. 8, items E and F. i. Upon evaluation of the 15 day written report submitted under Part IV.E. Le, the Commissioner may require the Permittee to sample appropriate media (soil, surface water, groundwater, air) as necessary to determine the extent of contamination. Further, upon review of the sampling analysis, the Commissioner may require the Permittee to submit a remediation plan for approval and to remediate the contaminated media affected by the release. Upon remediation, a final report summarizing remedial efforts taken shall be submitted to the Commissioner. 2. Containers If there should be a leak of hazardous waste from a storage container, the Permittee shall comply with the following requirements: a. The Permittee shall IMMEDIATELY inspect the containers to determine which container or containers are leaking. Having identified the leaking container or containers, the Permittee shall contain the spill as soon as possible. Any leaking container and adjacent or affected area shall be inspected by the Permittee to determine the reason for the leak. The contents of the container shall be overpacked into another container and be managed in accordance with Minn. R. 7045.0526, subp. 6, item C. b. Spilled or leaked waste, and accumulated precipitation from outdoor storage areas must be removed from the secondary containment system in a timely manner. If the collected material (including spill containment equipment and debris /residue) is a hazardous waste, the Permittee must manage the material in accordance with Minn. R. 7045.0526, subp. 6, item C. If the collected material is discharged through a point source to waters of the state, Minn. R. 7045.0526, subp. 6, item C must be followed. C. The Permittee shall notify the MPCA IMMEDIATELY after any leak or spill of hazardous waste to the environment if it is determined, based on the criteria in Part IV.G. of this Permit, that such notification is required. 29 of 67 EPA ID # MND006172969 April 2012 required. d. Part IV.L., of this Permit should be consulted to determine if a written report is e. The Commissioner may require the Permittee to sample appropriate media (soil, surface water, groundwater, air) as necessary to determine the extent of contamination. Further, upon review of the sampling analysis, the Commissioner may require the Permittee to remediate the contaminated media affected by the release. Upon remediation, a final report summarizing remedial efforts taken shall be submitted for approval to the Commissioner. F. RESPONSE TO OTHER SPILLS/LEAKS/RELEASES FROM NON - REGULATED UNITS If there should be a leak or spill of hazardous waste to the environment (escaping the secondary containment system) from any source at the Facility other than the Permitted regulated units, the Permittee shall comply with the following requirements: 1. The Permittee shall stop the leak or spill and clean up any released hazardous waste as soon as possible. 2. The Permittee must IMMEDIATELY conduct a visual inspection of the area around the leak or spill and prevent further migration of the leaked or spilled hazardous waste to soils and surface waters. 3. The Permittee shall notify the MPCA IMMEDIATELY after any leak or spill of hazardous waste to the environment if it is determined, based on the criteria in Part IV.G, of this Permit, that such notification is required. 4. In addition to the requirements in items 1 -3 above, the Permittee shall follow the procedures specified in Part IV, hereof (Emergency Procedures) if the leak should require implementation of the contingency plan. G. NOTIFICATION TO MPCA REGARDING SPILLS/LEAKS/RELEASES OF HAZARDOUS WASTE 1. Scope Minn. Stat. §§ 115.061 and 116.061 require notification to the MPCA regarding discharges to water and air, respectively, for any materials, including hazardous waste. Minn. R. 7045.0468, subp. 5, item B, and subp. 6 also provide requirements for reporting to the agency discharges of hazardous waste. Compliance under items 3 and 5 below satisfies the agency notification requirements regarding releases of hazardous waste at permitted hazardous waste facilities for both the rules and statutes cited above. 30 of 67 EPA ID # MND006172969 April 2012 All notifications required by items 3 and 5 below must be made to the Minnesota Duty Officer at one of the appropriate numbers provided below. Notification to the Minnesota Duty Officer satisfies the requirement for notifying the agency. TWIN CITIES METRO AREA (AND OUTSIDE MINNESOTA): 651- 649 -5451 GREATER MINNESOTA: 1- 800 - 422 -0798 2. Statutory Language MINN. STAT. § 115.061 DUTY TO NOTIFY AND AVOID WATER POLLUTION (a) Except as provided in paragraph (b), it is the duty of every person to notify the agency of the discharge, accidental or otherwise, of any substance or material under its control which, if not recovered, may cause pollution of waters of the State, and the responsible person shall recover as rapidly and thoroughly as possible such substance or material and take immediately such other action as may be reasonably possible to minimize or abate pollution of waters of the State caused thereby. (b) Notification is not required under paragraph (a) for a discharge of five gallons or less of petroleum, as defined in section 115C.02, subd 10. This paragraph does not affect the other requirements of paragraph (a). 3. Required Notification a. The following actions constitute compliance with the agency reporting requirements of Minn. Stat. § 115.061 and with Minn. R. 7045.046 8, subp. 5, item B, and subp. 6 regarding discharges of hazardous waste, other than releases to air, at permitted hazardous waste facilities. The Minnesota Duty Officer must be notified immediately of any of the following discharges: 1) A fire, explosion, or discharge that could threaten human health or the environment outside the Facility. 2) A discharge to the secondary containment of a permitted unit that is NOT completely contained in the secondary containment and /or is NOT recovered in a timely manner. 3) All discharges to areas outside of the containment systems described in Parts IV.G.3.a.1) and 2), above, that could cause pollution of soil, surface water, or groundwater. 31 of 67 EPA ID # MND006172969 April 2012 4. Statutory Language MINN. STAT. § 116.061. AIR POLLUTION EMISSIONS ABATEMENT Subd. 1. Emission notification required. (a) A person who controls the source of an emission must notify the agency immediately of excessive or abnormal unpermitted emissions that: (1) may cause air pollution endangering human health; (2) may cause air pollution damaging property; or (3) cause obnoxious odors constituting a public nuisance. (b) If a person who controls the source of an emission has knowledge of an event that has occurred and that will subsequently cause an emission described in paragraph (a), the person must notify the agency when the event occurs. Subd. 2. Abatement required A person who is required to notify the agency under subdivision 1 must take immediate and reasonable steps to minimize the emissions or abate the air pollution and obnoxious odors caused by the emissions. Subd. 3. Exemption. The following are exempt from the requirements of subdivisions 1 and 2: 1) emissions resulting from the activities of public fire services or law enforcement services; 2) emissions from motor vehicles, as defined in section 169.01, subdivision 3; 3) emissions from an agricultural operation deemed not a nuisance under section 561.19, subdivision 2; or 4) emissions from agency regulated sources that are routine or authorized by the agency. Subd. 4. Penalty exception A person who notifies the agency of emissions under subdivision 1 and who complies with subdivision 2 shall not be subject to criminal prosecution under section 115.071, subdivision 2. Subd. 5. Use of notification Any notice submitted under subdivision 1 is not admissible in any proceeding as an admission of causation. 32 of 67 EPA ID # MND006172969 April 2012 5. Required Notification Compliance with the statutory notification requirements above in Part IV.G.4, and the requirement below in Part IV.G.5, constitutes compliance with the agency reporting requirements of Minn. R. 7045.0468, subp. 5. item B, and subp. 6 regarding discharges of hazardous waste to the air at permitted hazardous waste facilities. Notification must be provided for a fire, explosion, or discharge that could threaten human health or the environment outside the facility. H. ADDITIONAL EMERGENCY COORDINATOR DUTIES AND NOTIFICATION TO OTHER AGENCIES [For reporting requirements regarding discovery of "noncompliance" with a condition of this Permit which could endanger human health or the environment, please refer to Part VI, of this Permit.] Whenever the contingency plan is implemented; the emergency coordinator shall IMMEDIATELY: 1. Activate internal Facility alarms or communication systems, 2. Identify the character, exact source, amount, and areal extent of any released material, 3. Assess possible hazards to human health or the environment, considering both direct and indirect effects of the release, fire, explosion; effects from any toxic, irritating, or asphyxiating gases that are generated; and effects of any hazardous surface water run -off from water or chemical agents used to control fire and explosions, and 4. Carry out the appropriate provisions of the Contingency Plan set forth in Section G of the Permit Application. If the emergency coordinator determines that: a. The hazardous waste or hazardous constituent release, fire, or explosion could threaten human health or the environment, inside or outside the Facility as defined in Part I, of this Permit, or b. Evacuation of local areas inside or outside the facility may be advisable, or C. A released hazardous waste or hazardous constituent may cause pollution of the air, land resources, or waters of the State, the emergency coordinator shall IMMEDIATELY notify: 1) Appropriate State and local authorities including but not limited to the Washington County Public Health & Environment Hazardous Waste Program, 33 of 67 EPA ID # MND006172969 April 2012 If the emergency coordinator determines that: a. The hazardous waste or hazardous constituent release, fire, or explosion could threaten human health or the environment, outside the Facility as defined in Part I, of this Permit, or b. Evacuation of local areas outside the Facility may be advisable, or C. A released hazardous waste or hazardous constituent may cause pollution of the air, land resources, or waters of the State, the emergency coordinator shall IMMEDIATELY notify: 2) The governmental official designated as the on -scene coordinator for that geographical area, or the National Response Center at (800) 424 -8802. The information in items a) through f) below shall be given to each of the above authorities at the time of the notification: a) Name and telephone number of reporter, b) Name and address of Facility, c) Date, time, and type of incident, d) Name and quantity of material involved, e) Extent of damages or injuries, if any, and f) The possible hazards to human health and /or the environment. I. CONTAINMENT MEASURES During an event that requires implementation of the Contingency Plan, the emergency coordinator shall ensure that releases, fires, and explosions do not occur, recur, or spread to other hazardous waste at the Facility. If the Facility stops operations, the emergency coordinator shall monitor for leaks, pressure build -up, gas generation, or ruptures in valves, pipes, or other equipment, wherever this is appropriate. J. POST EMERGENCY CLEANUP IMMEDIATELY after an event that requires implementation of the contingency plan, the Permittee shall provide for treating, storing, or disposing of recovered waste, contaminated soil, groundwater, and any other contaminated material resulting from the emergency incident at the Facility, in a manner required by applicable laws and rules. K. STARTUP OF OPERATIONS The Permittee shall not recommence operations after an emergency until the MPCA and local police and fire departments have been notified and the Facility is in compliance with Minn. R. 7045.0470, subp. 2. This requirement does not apply to an incident of emergency venting from 34 of 67 EPA ID # MND006172969 April 2012 the Komar shredder through its emergency vent stack, provided the Permittee has determined that the emergency venting does not have the potential to threaten human health or the environment. The Permittee shall keep a record in its operating records of the date of the use of its emergency vent stack, the length of time of the venting, and the reason for the venting. The Permittee shall also report the emergency venting in its annual report submitted under Part VI.C.1. L. POST EMERGENCY REPORTING WITHIN 15 DAYS after an event that requires implementation of the Contingency Plan as required by Minn. R. 7045.0466, subp. 3, and Part IV.H. of this Permit, the Permittee shall submit a written report to the Commissioner and the Washington County Department of Public Health & Environment Hazardous Waste Program describing the incident, containing information as required by Minn. R. 7045.0470, subp. 3. M. OPERATING RECORD The Permittee shall note in the operating record the time, date, and details of any incident that requires implementation of the contingency plan. N. EMERGENCY VENT STACK (DUMPSTACK) During periods when the Komar shredder is in operation, the emergency vent stack (dumpstack) of the waste shredder shall be used intentionally, only when plant or worker safety would be in jeopardy without its use. 35 of 67 EPA ID # MND006172969 April 2012 PART V. RECORDKEEPING REQUIREMENTS A. PLANS TO BE MAINTAINED AT THE FACILITY The Permittee shall maintain at the Facility at all times a copy of the most recent MPCA- approved version of the following plans: 1. A Waste Analysis Plan as set forth in Section C of the Permit Application, and that meets the requirements of Minn. R. 7045.0458. 2. A personnel training plan as set forth in Section K of the Permit Application, and that meets the requirements of Minn. R. 7045.0454. 3. A contingency plan as set forth in Section G of the Permit Application, and that meets the requirements of Minn. R. 7045.0466. 4. A closure plan as set forth in Section L of the Permit Application, and that meets the requirements of Minn. R. 7045.0486. 5. An inspection plan as set forth in Section E of the Permit Application, and that meets the requirements of Minn. R. 7045.0452, subp. 5. 6. Procedures that describe operational and maintenance procedures to be used at the Facility to ensure proper management of hazardous waste containers and tank systems and that meets the requirements of Minn. R. 7001.0570, subp. C, Minn. R. 7045.0526 and 7045.0528. B. OPERATING RECORD The Permittee shall keep a written or computerized operating record at the Facility that contains the information in Minn. R. 7045.0478, including the following information: 1. The names of each hazardous waste generator and its EPA identification number. 2. The arrival date of incoming hazardous waste, and the shipment date of outgoing hazardous waste, corresponding with the transporter's name and identification number. 3. A description and statement of the quantity of each hazardous waste received, or shipped, and the method and date when stored and incinerated. The Permittee shall also record the volume, waste code and estimated BTU value of all hazardous waste from non -3M sources processed at the facility. 36 of 67 EPA ID # MND006172969 April 2012 4. The location of each hazardous waste shipment or container within the Facility and the total quantity of hazardous waste at each location. This information must be complete and up to date at all times. This information must be cross - referenced to the manifest accompanying the waste. 5. The records and results of each waste analysis performed. 6. The records and results of each inspection performed. 7. The results of any monitoring performed at the Facility. 8. Summary reports and details of all incidents which required implementation of the Contingency Plan. 9. All annual reporting requirements specified in Part VI.C. of this Permit. 10. All Land Disposal Restricted waste notifications required by Minn. R. 7045.1390, which incorporates by reference 40 CFR § 268.7, with the exceptions to incorporation listed in Minn. R. 7045.1390. 11. A copy of the notices provided by the Permittee to each of the generators from whom the Permittee is obtaining hazardous wastes for storage at the Facility as required by Part III.B., hereof. 12. The date of use of the emergency vent stack (dumpstack) for the waste shredder, the length of time the dumpstack was used for venting and the reason for using the dumpstack for venting. 13. The date of and information about the release under Part IV.E.1.f. of this Permit, including the hazardous waste released, the quantity of the release, cleanup measures taken, and how the released material was managed. 14. A copy of the MPCA approved internal material handling procedures for management at the Facility of waste accepted from Minnesota law enforcement agencies and a copy of the MPCA approved material handling and packaging instructions that Minnesota law enforcement agencies must follow when delivering waste to the Facility. C. PERSONNEL RECORDS The Permittee shall maintain at the Facility at all times a copy of the following personnel records: 1. The job title for each position at the Facility related to hazardous waste management and the name of the employee filling each job. 37 of 67 EPA ID # MND006172969 April 2012 2. A written job description of each position at the Facility related to hazardous waste management. This description may be consistent in its degree of detail with descriptions for other similar positions in the same company location or bargaining unit, but must include at least the requisite skill, education, or other qualifications and duties of employees assigned to each such position. 3. A written description of the type and amount of both introductory and continuing training in accordance with the Personnel Training Plan set forth in Section K of the Permit Application, that will be given to each person filling a hazardous waste position referenced in item 1, above. 4. Records that document the training provided to each employee filling a position referenced in item 1 above. D. INSPECTION RECORDS The Permittee shall record all inspections in an inspection log. These records must include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. E. MONITORING AND TESTING RECORDS In accordance with Minn. R. 7001.0150, subp. 2, items B and C: 1. The Permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports and records required by this Permit, and records of all data used to complete the Application for this Permit. 2. Records of monitoring information shall specify: a. The date(s), exact place, and time(s) of sampling or measurements; b. The individual(s) who performed the sampling or measurements; C. The date(s) analyses were performed; d. The individual(s) who performed the analyses; e. The analytical techniques for methods used; and f. The results of such analyses. 38 of 67 EPA ID # MND006172969 April 2012 F. RETENTION AND DISPOSITION OF RECORDS The Permittee shall maintain all records for at least three (3) years after generation of the record unless the record is required by Minn. R. 7045.0478, subp. 3 or Minn. R. 7001.0720, subp. 2, item B to be kept for a longer period of time. Records required to be kept until closure of the Facility are listed in Minn. R. 7045.0478, subp. 3 and Minn. R. 7001.0720, subp. 2. These retention periods are automatically extended during the course of and at least for the duration of an unresolved enforcement action regarding the Permittee and shall also be extended upon request of the Commissioner. These records shall be made available to the Commissioner upon Request. 39 of 67 EPA ID # MND006172969 April 2012 PART VI. REPORTING REQUIREMENTS A. REPORTING NONCOMPLIANCE As used herein, the term "noncompliance" refers to any failure, intentional or unintentional, avoidable or unavoidable, to satisfy any requirement of this Permit. 1. If the Permittee discovers that noncompliance with a condition of the Permit has occurred, which could endanger human health, public drinking water supplies, or the environment, the Permittee shall, WITHIN 24 HOURS after the discovery of the noncompliance, orally notify the Commissioner. WITHIN FIVE (5) DAYS of the discovery of the noncompliance, the Permittee shall submit to the Commissioner a written description of the noncompliance; the cause of the noncompliance; the exact dates of the period of noncompliance; and, if the noncompliance has not been corrected, the anticipated time it is expected to continue and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance. 2. For noncompliance occurrences not required to be reported under Part VI. A.1, above, the Permittee shall submit a written report to the Commissioner WITHIN 30 DAYS after the noncompliance is discovered. B. REPORTING PLANNED CHANGES The Permittee shall give advance written notice to the Commissioner as soon as possible of any planned physical alteration of or addition to the Permitted Facility and of any activity that may result in noncompliance with its Permit or with any requirement of state or federal law. This notice does not relieve the Permittee of: The requirement to obtain a modification of this Permit or, 2. Any liability for noncompliance with this Permit or the law. C. ANNUAL REPORTING REQUIREMENTS 1. Annual Report The Permittee shall submit an annual report to the MPCA no later than March 1st of each year, for the previous calendar year. The annual report must include the information required by Minn. R. 7045.0482, subp. 2. and the requirements in Part IV.E.I.f and Part IV.K. 2. Financial Assurance for Closure with Applicable Cost Estimate Updates and Liability Coverage The Permittee shall by March 31st of each year submit to the MPCA updated closure financial assurance (with cost updates) and liability coverage, to reflect current financial conditions. 40 of 67 EPA ID # MND006172969 April 2012 3. Pollution Prevention. The Permittee shall certify each year at the time of submission of its annual report that a program is in place to reduce the volume and toxicity of waste and pollution to the maximum degree economically practicable, and that the method used to manage waste and pollution minimizes present and future threats to human health and the environment to the extent practicable as required by Minn. R. 7045.0478, subp. 3.K. The program shall consist of a plan which includes these elements: a. A policy statement articulating upper management support for eliminating or reducing the generation of waste and pollution at the facility. b. A description of the current processes generating or releasing waste and pollution that specifically describes the types, sources, and quantities of waste and pollution currently being generated. C. A description of the current and past practices used to eliminate or reduce the generation of waste and pollution and an evaluation of the effectiveness of these practices. d. An assessment of technically and economically practicable options available to eliminate or reduce the generation of waste and pollution. e. A statement of waste and pollution reduction objectives based on the assessment in clause d. above, and a schedule for achieving those objectives. f. An explanation of the rationale for each waste and pollution reduction objective. g. A listing of options that were considered not to be economically and technically practicable. 4. Fees. The Permittee shall pay the required annual facility fee as specified in Minn. R. 7046.0020. D. NOTIFICATIONS AND SUBMITTALS ON AIR EMISSIONS FROM EQUIPMENT LEAKS; TANKS, SURFACE IMPOUNDMENTS, AND CONTAINERS; AND PROCESS VENTS The Permittee shall maintain notifications and submittals, as required by PART XII.B.2.; C.2.; and D.2., respectively, of this Permit E. CERTIFICATION AND SIGNATORY REQUIREMENTS All reports or other information required to be submitted to the Commissioner in accordance with the terms and conditions of this Permit shall carry the certification required by Minn. R. 7001.0070 and 7001.0540. 41 of 67 EPA ID # MND006172969 April 2012 F. SUBMITTAL OF WRITTEN REPORTS All written reports required to be submitted by the Permittee shall be sent to: Manager Land and Air Compliance Section Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155 -4194 42 of 67 EPA ID # MND006172969 April 2012 PART VII. CLOSURE A. NOTIFICATION OF CLOSURE The Permittee shall notify the Commissioner at least 45 days prior to the expected date of commencement of full or partial closure of the Facility. The written notice shall include: 1. The anticipated last day of operation; 2. The existing inventory count and inventory reduction schedule; and 3. A discussion of how conditions of this Permit and state and federal law will be met. B. CLOSURE PLAN If the Permittee shall decide to close all or a portion of the hazardous waste Facility, the Permittee shall close in accordance with the MPCA- approved closure plan in effect at the time. The present MPCA- approved closure plan is set forth in Section L of the Permit Application. The MPCA may require additional closure work plans to be developed if necessary to reflect Facility specific closure or partial closure activities to be conducted. C. TIME ALLOWED FOR CLOSURE After receiving the final volume of hazardous waste at the Facility, the Permittee shall remove all hazardous wastes in accordance with the closure plan schedule in effect at the time, which shall not exceed 180 days unless approved by the Commissioner. The present closure schedule is detailed in the closure plan set forth in Section L.6 of the Permit Application. D. CERTIFICATION OF CLOSURE WITHIN 60 DAYS after closure is completed, the Permittee shall submit to the Commissioner a certification signed by the Permittee and by an independent registered professional engineer that the Facility has been closed in accordance with the MPCA- approved closure plan and any additional closure work plans if developed. The certification shall contain language as stated in Minn. R. 7001.0070 and 7001.0540. 43 of 67 EPA ID # MND006172969 April 2012 PART VIII. CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS Minn. R. 7045.0485 requires that the owner or operator of a facility seeking a hazardous waste facility permit conduct corrective action for releases of hazardous waste or constituents from any hazardous or solid waste management unit at the facility. Section N of the Permit Application describes solid waste management units and remediation that is being conducted and has been conducted at these units. Based on information gathered to date, the Permittee maintains there are no known other releases of hazardous waste or constituents requiring corrective action from any solid or hazardous waste management units (as defined in Minn. R. 7045.0020, subp. 36) at the Facility. If any information becomes available concerning releases from solid or hazardous waste management units, the Permittee shall notify the Commissioner. If necessary, the Commissioner will then proceed to commence an action to modify this Permit to require the Permittee to undertake appropriate corrective action in accordance with Minn. R. 7045.0485. 44 of 67 EPA ID # MND006172969 April 2012 PART IX. GENERAL CONDITIONS A. NO RELEASE FROM LIABILITY Issuance of this Permit by the MPCA does not release the Permittee from any liability, penalty, or duty imposed by Minnesota or federal statutes, rules or local ordinances, except the obligation to obtain this Permit. B. THIRD PARTY LIABILITY Issuance of this Permit by the MPCA does not release the Permittee from or affect any liability which the Permittee may incur as a result of the operation of the Permitted Facility. C. FUTURE RULES This Permit does not prevent the future adoption by the MPCA of pollution control rules, standards, or orders more stringent than those now in existence and does not prevent or affect the enforcement of these rules, standards, or any orders against the Permittee. D. PROPERTY RIGHTS This Permit does not convey a property right or an exclusive privilege. E. OBLIGATION TO ENFORCE This Permit does not obligate the MPCA or the Commissioner to enforce laws, rules, or plans. F. LIABILITY/RESPONSIBILITY This Permit authorizes the Permittee to perform the activities described in this Permit under the conditions of this Permit. In issuing this Permit, the State and Commissioner assume no responsibility for injury to persons or damage to property or the environment caused by the activities of the Permittee including those activities authorized, directed, or undertaken under this Permit. To the extent the State and Commissioner may be liable for the activities of State employees, that liability is explicitly limited to that provided in the Tort Claims Act, Minn. Stat. § 3.736. 45 of 67 EPA ID # MND006172969 April 2012 G. DEFENSE UNDER OTHER STATUTES AND RULES Compliance with the terms of this Permit does not constitute a defense to any action brought under Section 7003 of the Resource Conservation and Recovery Act, Section 106(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9601 et seq., commonly known as CERCLA), the Minnesota Environmental Response and Liability Act of 1983 (Minn. Stat. ch. 11513), Minn. Stat. chs. 116, 400, 473, or any other Minnesota or Federal statutes, rules or regulations, or local ordinances. H. MINIMUM STANDARDS This Permit establishes minimum standards for the operation of the permitted Facility. Nothing in this Permit precludes the Permittee from taking additional steps to protect the public health or welfare or the environment so long as these additional steps are not inconsistent with the terms and conditions of this Permit. The Permittee is solely responsible for ensuring that the Permitted Facility adequately safeguards public health and welfare and the environment. I. DUTY TO COMPLY The Permittee shall perform the actions and conduct the activity authorized by this Permit in accordance with the plans and specifications approved by the MPCA and in compliance with the conditions of this Permit and applicable local, state, and federal hazardous waste laws, rules, ordinances, and regulations. J. POLLUTION PREVENTION In accordance with Part VI.C.3, the Permittee shall certify at least annually that it has a program in place to reduce the volume and toxicity of the waste and pollution to the maximum degree economically practicable, and that the method used to manage the waste and pollution minimizes present and future threats to human health and the environment to the extent practicable. The program shall consist of a plan which includes the elements stated in Part VI.C.3 of this permit. K. FALSE STATEMENTS The Permittee shall not knowingly make a false or misleading statement, representation, or certification in a record, report, plan or other document submitted to the MPCA or to the Commissioner. The Permittee shall IMMEDIATELY upon discovery report to the Commissioner an error or omission in any such record, report, plan, or other document. 46 of 67 EPA ID # MND006172969 April 2012 L. DUTY TO PROVIDE INFORMATION The Permittee shall, when requested by the Commissioner, submit within a reasonable time the information and reports that are relevant to the control of pollution, regarding the construction or operation of the Facility covered by this Permit, or regarding the conduct and the activity covered by this Permit, in accordance with Minn. Stat. §§ 115.04 and 116.07, subd. 9. M. INSPECTION AND ENTRY When authorized by Minn. Stat. §§ 115.04, 115B.17, subd. 4, or 116.091, and upon presentation of proper credentials, the MPCA, or an authorized employee or agent of the MPCA, shall be allowed by the Permittee to examine and copy books, papers, records, or memoranda pertaining to the construction, modification, or operation of the Facility covered by this Permit or pertaining to the activity covered by this Permit. N. DUTY TO MITIGATE If the Permittee discovers, through any means, including notification by the MPCA, that noncompliance with a condition of the Permit has occurred, the Permittee shall promptly take all reasonable steps to minimize the adverse impacts on human health, public drinking water supplies, or the environment resulting from the noncompliance. O. BANKRUPTCY 1. Notification of Bankruptcy The Permittee shall notify the Commissioner by certified mail of the commencement of a voluntary or involuntary proceeding under United States Code, Title 11, Bankruptcy, naming the Permittee as debtor, WITHIN TEN (10) DAYS after commencement of the proceeding. 2. Incapacity of Financial Assurance and Liability Coverage The Permittee currently meets the requirements regarding Financial Assurance for Closure through use of a Financial Test and Corporate Guarantee and for Liability Coverage through the use of a Financial Test. The Permittee shall be deemed to be without such required financial assurance or liability coverage at any time that the Permittee is no longer able to satisfy the applicable requirements of the financial test as established in Minn. R. 7045.0504, subp. 7, and 7045.0518, subp. 6. If at any time during the term of the Permit, any financial institution or insurer providing such financial assurance or liability coverage is involved in bankruptcy proceedings, the Permittee shall be deemed to be without such required financial assurance or liability coverage. In such event, the Permittee shall have 60 days, upon notifying the MPCA of the bankruptcy proceeding, to obtain other means of financial assurance and liability coverage. Failure to do so shall constitute a violation of this Permit. 47 of 67 EPA ID # MND006172969 April 2012 P. MODIFICATION, REVOCATION, AND REISSUANCE OF THIS PERMIT This Permit may be modified, revoked and reissued, or revoked without reissuance for cause, as specified in Minn. R. 7001.0170 to 7001.0190 and Minn. R. 7001.0730. The filing of a request for a Permit Modification, Revocation and Reissuance, or Revocation without Reissuance, or the notification of planned changes or anticipated noncompliance on the part of the Permittee does not stay or affect the applicability or enforceability of a Permit condition. Requests for modification of plans or specifications integral to this Permit must be approved by the Commissioner prior to implementing the requested change. Q. OPERATION DURING REISSUANCE PERIOD If the Permittee wishes to continue an activity allowed by this Permit after the expiration date of this Permit, the Permittee shall submit a complete Application for reissuance of the Permit at least 180 calendar days before this Permit expires, unless written permission for a later date has been granted by the Commissioner. R. CONTINUATION OF EXPIRED PERMIT This Permit will remain in effect beyond the Permit's expiration date if the Permittee has submitted a timely and complete Application for reissuance of the Permit provided that the Commissioner determines, based on available information, that all of the following are true: 1. The Permittee is in compliance with the terms and conditions of the expired Permit; 2. The Permittee continues at all times to work diligently and in good faith to meet the requirements and satisfy the concerns of the Commissioner with respect to the Permit Application; and 3. The Commissioner, through no fault of the Permittee, has not taken final action on the Application before the expiration date of this Permit. S. TRANSFER OF PERMITS This Permit is not transferable to any person without the express written approval of the MPCA, and then only after compliance with the requirements of Minn. R. 7001.0190 and 7045.0452, subp. 3. item D. A party to whom this Permit has been transferred shall comply with the terms and conditions of this Permit. 48 of 67 EPA ID # MND006172969 April 2012 T. SEVERABILITY The provisions of this Permit are severable, and if any provision of this Permit, or the application of any provision of this Permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this Permit shall not be affected thereby. U. EMERGENCY PERMITS The Permittee need not comply with the conditions of this Permit to the extent and for the duration that the noncompliance is authorized in an emergency Permit in accordance with Minn. R. 7001.0690. V. AUTHORIZED SIGNATURES The Permittee may allow an authorized representative to sign reports submitted in accordance with the requirements of this Permit in accordance with the conditions of Minn. R. 7001.0720, subp. 2, item F. 49 of 67 EPA ID # MND006172969 April 2012 PART X. REVIEW OF SUBMITTALS AND EXTENSION OF SCHEDULES A. REVIEW OF SUBMITTALS The review of each submittal, document, report, or schedule (collectively referred to hereafter as "submittal ") which is required to be submitted to the Commissioner for review and approval shall be as follows: 1. The Commissioner shall review each submittal made by the Permittee as required by this Permit. In the event the submittal is approved, it shall become an integral and enforceable part of this Permit. If the submittal is disapproved in whole or part, the Commissioner shall notify the Permittee in writing and shall explain the amendments or revisions that are necessary to bring the submittal into compliance with this Permit. 2. Within 30 calendar days of receipt of any notice of disapproval or modification, or on the first working day thereafter (if said 30th day fell on a Sunday or Holiday) the Permittee shall: a. Submit revisions to correct inadequacies that led to disapproval, or, b. State in writing the reasons why the submittal, as originally submitted, should be approved. The Permittee may have longer than 30 days to respond if the longer time period is specified in the Commissioner's review letter referenced in paragraph 1. 3. If, within 30 calendar days from the date of the Permittee submission under paragraph 2, above, the parties have not reconciled all issues with respect to the submittal, the Commissioner shall inform the Permittee of the second disapproval of the submittal and whether in the Commissioner's view, the Permittee may be in violation of the Permit. In such event, the matter may be referred for enforcement action. 4. The Commissioner and the Permittee shall provide the opportunity to consult with each other during the review of submittals or modifications. B. EXTENSION OF SCHEDULES All time extensions must be requested by the Permittee in writing. The requests shall specify the reasons why the extension is needed. Extensions shall only be granted for such a period of time as the Commissioner determines is reasonable under the circumstances. A requested extension shall not be effective until approved by the Commissioner. The burden shall be on the Permittee to demonstrate to the satisfaction of the Commissioner that the request for the extension has been submitted in a timely fashion and that good cause exists for granting the extension and that the extension shall have no adverse effect upon human health or the environment. 50 of 67 EPA ID # MND006172969 April 2012 Extension of compliance schedule dates provided in this Permit may be granted if requests are submitted in a timely fashion and good cause exists for granting the extension, and if the extension would have no adverse effect upon human health or the environment. 51 of 67 EPA ID # MND006172969 April 2012 PART XI. LAND DISPOSAL REQUIREMENTS A. GENERAL CONDITIONS 1. The Permittee shall comply with all applicable land disposal restrictions in Minn. R. 7045.1390, which incorporates by reference 40 CFR pt. 268, with the exceptions to incorporation listed in Minn. R. 7045.1390 and 7045.0090. All of the requirements in this Part XI are subject to the exceptions to incorporation listed in Minn. R. 7045.1390 and Minn. R. 7045.0090. 2. A mixture of any restricted waste with any nonrestricted waste is a restricted waste under 40 CFR § 268.1. 3. The Permittee shall not in any way dilute a restricted waste or the residual from treatment of a restricted waste as a substitute for adequate treatment to achieve compliance with the treatment standards in 40 CFR pt. 268, subp. D, to circumvent the effective date of a prohibition in 40 CFR pt. 268, subp. C, to otherwise avoid compliance with a prohibition in 40 CFR pt. 268, subp. C, or to circumvent a land disposal prohibition imposed by Section 3004 of RCRA. 4. The Permittee shall prepare and maintain a current list of the hazardous waste codes for all wastes handled at the Facility that are identified or listed in 40 CFR §§ 268.20 -.39. The list shall include all wastes and waste codes handled at the Facility, and any associated treatment standards, and shall be updated through the inclusion of new treatment standards, as promulgated or amended. This list shall be provided to the MPCA representatives, or its designees, upon request. B. TESTING AND RELATED REQUIREMENTS 1. The Permittee shall test, in accordance with 40 CFR § 268.7, any waste generated at the Facility, or use knowledge of the waste, to determine if the waste is restricted from land disposal. 2. For restricted wastes with treatment standards expressed as concentrations in the waste extract, as specified in 40 CFR § 268.40, the Permittee shall test the treatment residues, or an extract of such residues developed using the test methods described in 40 CFR § 268.40(b) (Method 1311, (Toxicity Characteristic Leaching Procedure or TCLP) to assure that the treatment residues or extract meet the applicable treatment standards of 40 CFR § 268.40. Such testing shall be performed pursuant to the requirements of Minn. R. 7045.045 8, subp. 1. 3. A restricted waste for which a treatment technology is specified in 40 CFR § 268.42 may be land disposed after it is adequately treated using that specified technology or an equivalent treatment method approved by the EPA under the procedures set forth in 40 CFR § 268.42. 52 of 67 EPA ID # MND006172969 April 2012 4. For restricted wastes with treatment standards expressed as concentrations in the waste, as specified in 40 CFR § 268.40, the Permittee shall test the treatment residues (not an extract of such residues) to assure that the treatment residues meet the applicable treatment standards of 40 CFR § 268.40. Such testing shall be performed as required by 40 CFR § 268.40. C. STORAGE PROHIBITIONS 1. The Permittee shall comply with all the applicable prohibitions on storage of restricted wastes specified in 40 CFR § 268.50. 2. The Permittee may store restricted wastes in tanks and containers solely for the purpose of the accumulation of such quantities of hazardous wastes as necessary to facilitate proper recovery, treatment, or disposal provided that: a. Each container is clearly marked to identify its contents and the date each period of accumulation begins. b. Each tank is clearly marked with a description of its contents, the quantity of each hazardous waste received, and the date each period of accumulation begins, or such information for each tank is recorded and maintained in the operating record at the Facility. 3. The Permittee may store restricted wastes for up to one (1) year unless the MPCA can demonstrate that such storage was not solely for the purpose of accumulating such quantities of hazardous waste as are necessary to facilitate proper recovery, treatment or disposal. 4. The Permittee may store restricted wastes beyond one (1) year provided that the Permittee proves that such storage was solely for the purpose of accumulating such quantities of hazardous waste as are necessary to facilitate proper recovery, treatment or disposal. 5. Any liquid hazardous waste containing polychlorinated biphenyls (PCBs) at concentrations greater than or equal to 50 ppm must be removed from storage and treated or disposed within one (1) year of the date when such wastes are first put into storage. Part XI.C.4 above, which allows storage for over one (1) year with specified demonstration, does not apply to PCB wastes. D. BLENDING OF METAL WASTES Combustion of metal- bearing wastes (listed in Apendix XI of 40 CFR Part 268) is prohibited unless the Permittee has demonstrated to the MPCA that the waste, at the point of generation, or after bona fide treatment such as cyanide destruction prior to combustion, complies with one or more of the criteria specified in 40 CFR § 268.3(c). 53 of 67 EPA ID # MND006172969 April 2012 PART XII. AIR EMISSIONS OF ORGANIC COMPOUNDS A. COORDINATION WITH THE CLEAN AIR ACT This Permit does not release the Permittee from any requirements in the Clean Air Act, Minnesota laws or rules applicable to air emission facilities, or air emission facility permits issued by the MPCA or EPA. Except as explicitly stated in this Permit, this Permit does not supersede or waive any hazardous waste requirements in favor of air emission facility requirements. The Permittee must comply with all relevant requirements of 40 CFR Parts 60, 61 and 63 regarding air emission standards for equipment leaks, tanks, surface impoundments, containers and process vents. Documentation of compliance with the relevant provisions of 40 CFR Parts 60, 61 or 63 shall be kept at the Facility and made available for inspection. In addition, the Permittee shall provide such documentation to the MPCA upon written request. B. EQUIPMENT LEAKS 1. Applicability. The Permittee must comply with all applicable requirements of Minn. R. 7045.055 1, which incorporates by reference 40 CFR § 264.1050 through 40 CFR § 264.1065, (Subpart BB), with the exceptions to incorporation listed in Minn. R. 7045.0551, regarding air emission standards for equipment leaks except if compliance is demonstrated as allowed in Part XII.B.2 of this Permit. A list of all components subject to Subpart BB is found in Section T of the Permit Application. The Permittee must keep at the Facility a list of all the components subject to Subpart BB and the specific section that is applicable. Specifically, equipment at the Permittee's Facility is subject to the following standards: 40 CFR § 264.1050 Applicability 40 CFR § 264.1051 Definitions 40 CFR § 264.1052 Standards: Pumps in light liquid service 40 CFR § 264.1053 Standards: Compressors 40 CFR § 264.1054 Standards: Pressure relief devices in gas /vapor service 40 CFR § 264.1055 Standards: Sampling connection systems 40 CFR § 264.1056 Standards: Open -ended valves or lines 40 CFR § 264.1057 Standards: Valves in gas /vapor or light liquid service 40 CFR § 264.1058 Standards: Pumps and valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service and flanges and other connectors 54 of 67 EPA ID # MND006172969 April 2012 40 CFR § 264.1059 Standards: Delay of repair 40 CFR § 264.1060 Standards: Closed vent systems and control devices 40 CFR § 264.1063 Test methods and procedures 40 CFR § 264.1064 Recordkeeping requirements 40 CFR § 264.1065 Reporting requirements The Permittee shall not operate pressure relief devices, sampling connection systems, or open ended valves or lines subject to Subpart BB unless and until it obtains a permit modification pursuant to Part IX.P. of this Permit. The alternative standards at 40 CFR §§ 264.1061 and 264.1062 shall not be applied to equipment subject to Subpart BB at the Facility unless and until a permit modification is obtained pursuant to Part IX.P. of this Permit. 2. Clean Air Act Alternative Compliance If any of the equipment subject to Subpart BB is also subject to the Clean Air Act regulations at 40 CFR Parts 60, 61, or 63, then 40 CFR § 264.1064(m) allows the Permittee to elect to determine compliance with Subpart BB by documenting compliance with the relevant provisions of 40 CFR Parts 60, 61, or 63. Such documentation shall be kept at the Facility and made available for inspection according to 40 CFR § 264.1064(m). In addition, the Permittee shall provide such documentation to the MPCA upon written request. C. TANKS, SURFACE IMPOUNDMENTS, AND CONTAINERS 1. Applicability. The Permittee must comply with all applicable requirements of Minn. R. 7045.0540, which incorporates by reference, 40 CFR § 264.1080 through 40 CFR § 264.1090 (Subpart CC), with the exceptions to incorporation listed in Minn. R. 7045.0540 regarding air emission standards for Tanks, Surface Impoundments, and Containers except if the Permittee certifies compliance under the Clean Air Act as allowed in Part XII.C.2 of this Permit. A list of all components subject to Subpart CC is found in Section T of the Permit Application. The Permittee must keep at the Facility a list of all the components subject to Subpart CC and the specific section that is applicable. Specifically, equipment at the Permittee's Facility is subject to the following standards: 40 CFR § 264.1080 40 CFR § 264.1081 40 CFR § 264.1082 40 CFR § 264.1083 40 CFR § 264.1084 40 CFR § 264.1086 Applicability Definitions Standards: General Waste Determination Procedures Standards: Tanks Standards: Containers 55 of 67 EPA ID # MND006172969 April 2012 40 CFR § 264.1087 Standards: Closed -vent systems and Control Devices 40 CFR § 264.1088 Inspection and Monitoring Requirements 40 CFR § 264.1089 Recordkeeping Requirements 40 CFR § 264.1090 Reporting Requirements The Permittee shall not operate tanks, containers, or closed -vent systems and control devices subject to Subpart CC unless and until it obtains a permit modification pursuant to Part IX.P. of this Permit. 2. Clean Air Act Alternative Compliance According to 40 CFR § 264.1080(b)(7) the requirements of Subpart CC do not apply to a hazardous waste management unit that the owner or operator certifies is equipped with and operating air emission controls in accordance with the requirements of an applicable Clean Air Act regulation codified under 40 CFR Part 60, Part 61, or Part 63. Certification that the waste management unit is equipped with and operating air emissions controls in accordance with the requirements of the Clean Air Act regulations at 40 CFR part 60, 61, or 63 shall be kept at the Facility and made available for inspection according to 40 CFR § 264.10890). In addition, the Permittee shall provide such documentation to the MPCA upon written request. D. PROCESS VENTS 1. Applicability. The Permittee must comply with all applicable requirements of Minn. R. 7045.0549, which incorporates by reference, 40 CFR § 264.1030 through 40 CFR § 264.1036 (Subpart AA), with the exceptions to incorporation listed in Minn. R. 7045.0549 regarding air emission standards for Process Vents except if the Permittee certifies compliance under the Clean Air Act as allowed in Part XII.D.2 of this Permit. A list of all components subject to Subpart AA is found in Section T of the Permit Application. The Permittee must keep on site a list of all the components subject to Subpart AA and the specific section that is applicable. Specifically, equipment at the Permittee's Facility is subject to the following standards: 40 CFR § 264.1030 40 CFR § 264.1031 40 CFR § 264.1032 40 CFR § 264.1033 40 CFR § 264.1034 40 CFR § 264.1035 40 CFR § 264.1036 Applicability Definitions Standards: Process Vents Standards: Closed -vent Systems and Control Devices Test Methods and Procedures Recordkeeping Requirements Reporting Requirements 56 of 67 EPA ID # MND006172969 April 2012 The Permittee shall not operate process vents or closed -vent systems and control devices subject to Subpart AA unless and until it obtains a permit modification pursuant to Part IX.P. of this Permit. 2. Clean Air Act Alternative Compliance According to 40 CFR § 264.1030(e) the requirements of Subpart AA do not apply to the process vents at a facility where the Permittee certifies that all of the process vents that would otherwise be subject to Subpart AA are equipped with and operating air emission controls in accordance with the process vent requirements of an applicable Clean Air Act regulation codified under 40 CFR Part 60, Part 61, or Part 63. Certification that the waste management unit is equipped with and operating air emissions controls in accordance with the requirements of the Clean Air Act regulations at 40 CFR Part 60, 61, or 63 shall be kept at the Facility and made available for inspection. In addition, the Permittee shall provide such documentation to the MPCA upon written request. E. INCINERATOR The Permittee shall comply with all applicable requirements of Minn. R. 7045.0551. The Permittee shall also comply with the Performance Standards, Operating Conditions, and Performance Test Requirements in Part XIII of this Permit as well as the requirements of 40 CFR Part 63, Subpart EEE. If the MPCA determines that a violation of 40 CFR Part 63, Subpart EEE of Air Emissions Permit No. 16300025 -002 also results in a violation of the same requirement included in this Permit, then the MPCA shall initiate an enforcement action for the violation(s) of this Permit only if the MPCA first determines that enforcement under Air Emissions Permit No. 16300025 -002 is inadequate to remedy the violation(s). F. NOTIFICATION OF REGULATED ACTIVITY The Permittee shall notify the MPCA of any waste management units which become subject to the requirements of Minn. R. 7045.0551, 7045.0549 and 7045.0540, within 30 days of startup of the regulated activity. 57 of 67 EPA ID # MND006172969 April 2012 PART XIII. INCINERATOR PERFORMANCE STANDARDS 58 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable Emission Limits 1 Destruction and Removal Efficiency (DRE) Minn. R. 7045.0542 Compliance with the of 99.99% for Principle Organic Hazardous subp. 4A Feedrate limits and Constituent (POHCs) in trial burn Operating Limits and General Operating Requirements listed below 2 Hydrogen Chloride (HCl) emissions to the Minn. R. 7045.0542, Compliance with the atmosphere must be no greater than the subp. 4B Feedrate limits and larger of either 1.8 kilograms per hour or Operating Limits and I% of the hydrogen chloride in the stack General Operating gas prior to entering any pollution control Requirements listed equipment. below 3 Particulate matter less than 180 milligrams Minn. R. 7045.0542, Compliance with the per Dry Standard Cubic Meter (DSCM) subp. 4C Feedrate limits and (0.08 grains per DSCF) corrected to Operating Limits and 7% oxygen General Operating Requirements listed below 4 Carbon Monoxide (CO) less than or equal Minn. R. 7045.0542, Carbon monoxide CEM, to 100 ppm using a 1 -Hour Rolling subp. 6.B. reported to the nearest Average ppm using a one -hour rolling average, in conjunction with oxygen CEM Feedrate Limits 5 Process Throughput: Less than or equal to To ensure that 1 -Hour Rolling Average 21,800 lbs/hr using 1 -hour Rolling Average operation remains of total hazardous waste to the kiln. within emission limits Minn. R. 7045.0542, subp. 6(B) 6 Process Throughput: Less than or equal to To ensure that 1 -Hour Rolling Average 14,800 lbs/hr using 1 -hour Rolling Average operation remains of total pumpable waste to the kiln. within emission limits " Pumpable" is defined in the compliance performance test. Minn. R. 7045.0542, subp. 6(B) 7 Process Throughput: Less than or equal to To ensure that 1 -Hour Rolling Average 300 lbs /hr using 1 -hour Rolling Average of operation remains total waste feed rate to the secondary within emission limits combustion chamber (SCC). Minn. R. 7045.0542, subp. 6(B) 58 of 67 EPA ID # MND006172969 April 2012 59 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis f Applicable Feedrate Limits 8 Process Throughput: Less than or equal to To ensure that 12 -Hour Rolling Average 3,410 lbs/hr using 12 -hour Rolling Average operation remains of ash fed to the system. within emission limits Minn. R. 7045.0542, subp. 6(B) 9 Chlorine: Less than or equal to 735 lbs/hr To ensure that 12 -Hour Rolling Average using 12 -hour Rolling Average fed to the operation remains system. within emission limits Minn. R. 7045.0542, subp. 6(B) 10 Mercury: Less than or equal to To ensure that 12 -Hour Rolling Average 0.0040 lbs/hour using 12 -hour Rolling operation remains Average fed to the system and 15 lbs /yr within emission limits using 12 month rolling sum. Minn. R. 7045.0542, subp. 6(B) 11 Semi - Volatile Metals (SVM) - Pb, Cd: less To ensure that 12 -Hour Rolling Average than or equal to 2.47 lbs/hour combined, operation remains using 12 -hour rolling average fed to the within emission limits system using the minimum of the following: Minn. R. 7045.0542, 1. The approved feedrate extrapolation subp. 6(B) level; 2. The MTEC calculated to demonstrate compliance with 40 CFR 63.1219(a)(3). 12 Low - Volatile Metals (LVM) - As, Be, Cr: To ensure that 12 -Hour Rolling Average less than or equal to 12.0 lbs/hr combined, operation remains using 12 -hour rolling average fed to the within emission limits system using the minimum of the following: Minn. R. 7045.0542, 1. The approved feedrate extrapolation subp. 6(B) level; 2. The MTEC calculated to demonstrate compliance with 40 CFR 63.1219(a)(3). 59 of 67 EPA ID # MND006172969 April 2012 60 of 67 EPA ID # MND006172969 April 2012 13 Pumpable LVM: less than or equal to To ensure that 12 -Hour Rolling Average 10.0 lbs/hr combined, using 12 -hour rolling operation remains average fed to the system using the within emission limits minimum of the following: 1. The approved feedrate extrapolation Minn. R. 7045.0542, level; subp. 6(B) 2. The MTEC calculated to demonstrate compliance with 40 CFR 63.1219(a)(3) Compliance Performance Demonstration Standards No. Requirement Basis f Applicable Feedrate Limits 14 Dioxins and Furans: less than or equal to To ensure that 0.40 ng TEQ /dscm corrected to 7% oxygen. operation remains TEQ = Toxicity Equivalents within emission limits Minn. R. 7045.0542, subp. 6(B) 15 The burning of dioxin/f Iran- listed wastes To ensure that F020, F021, F022, F023, F026, or F027 operation remains (see 40 CFR 261.31) is prohibited. within emission limits Minn. R. 7045.0542, subp. 6(B) Operating Limits 16 Temperature: greater than or equal to Minn. R. 7045.0542, 1 -Hour Rolling Average 1760 degrees F using 1 -Hour Rolling subp. 6.B.(3) Average for a minimum kiln exit gas temperature while burning waste. The temperature measurement location shall be as documented in the test plans submitted under 40 CFR 63.1207(e) 17 Temperature: greater than or equal to Minn. R. 7045.0542, 1 -Hour Rolling Average 1710° F. using 1 -Hour Rolling Average for subp. 6.B.(3) a minimum SCC exit gas temperature while burning waste. The temperature measurement location shall be as documented in the test plans submitted under 40 CFR 63.1207(e) 18 Air Flow Rate: less than or equal to 39,700 Minn. R. 7045.0542, 1 -Hour Rolling Average dry standard cubic feet/minute using 1- subp. 6.B.(4) Hour Rolling Average for a maximum flue gas flow rate. 19 Air Flow Rate: greater than or equal to Minn. R. 7045.0542, 12 -Hour Rolling Average 33,100 dry standard cubic feet /minute using subp. 6.B.(4) 12 -Hour Rolling Average (937 dscm/min) as a minimum flue gas flow rate. 60 of 67 EPA ID # MND006172969 April 2012 61 of 67 EPA ID # MND006172969 April 2012 20 The Permittee shall maintain a minimum Minn. R. 7045.0542, 1 -Hour Rolling Average atomization pressure of 31 PSIG in the subp. 6.B.(6) burner and the lances using 1 -Hour Rolling Average. Control 21 Subcooling Vessel Liquid Flow Rate: Minn. R. 7007.0800, 1 -Hour Rolling Average Equipment greater than or equal to 3250 subp. 14 Operating gallons /minute using 1 -Hour Rolling Requirements Average for recirculation water flow. 61 of 67 EPA ID # MND006172969 April 2012 62 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable Control 22 Subcooling Vessel Water pressure: greater Minn. R. 7007.0800, 1 -Hour Rolling Average Equipment than or equal to 19.40 psi (gauge) using subp. 14 Operating 1 -Hour Rolling Average minimum scrubber Requirements liquor feed pressure. 23 Subcooling Vessel Water Flow Rate: Minn. R. 7007.0800, 1 -Hour Rolling Average Greater than or equal to 194.0 gallons /min subp. 14 using 1 -Hour Rolling Average minimum combined blow down rate for the Subcooling Vessel and the Venturi Quench. 24 Subcooling Vessel pH: greater than or Minn. R. 7007.0800, 1 -Hour Rolling Average equal to 1.5 pH using 1 -Hour Rolling subp. 14 Average of the Scrubber Liquor. 25 Ml Module Pressure Drop: less than or Minn. R. 7007.0800, 1 -Hour Rolling Average equal to 16.1 inches of water column using subp. 14 1 -Hour Rolling Average. 26 Ml Module Water Flow Rate: greater than Minn. R. 7007.0800, 1 -Hour Rolling Average or equal to 128.0 gallons /min. using 1 -Hour subp. 14 Rolling Average minimum make -up rate. (As approved alternative to comply with minimum blow down rate limit). 27 Ml Module Liquid to Gas (L /G) Ratio: Minn. R. 7007.0800, 1 -Hour Rolling Average greater than or equal to 39.0 gallons per subp. 14 1000 standard cubic feet using a 1 -Hour Rolling Average. 28 Venturi Quench: Temperature: less than or Minn. R. 7007.0800, 1 -Hour Rolling Average equal to 182° F. using 1 -hr Rolling Average subp. 14 for the quench outlet flue gas temperature. 29 Venturi Quench Water Flow Rate: greater Minn. R. 7007.0800, 1 -Hour Rolling Average than or equal to 194.0 gallons /min. using subp. 14 1 -Hour Rolling Average minimum combined blow down rate for the Subcooling Vessel and the Venturi Quench. 30 Electrostatic Precipitator Total Power Minn. R. 7007.0800, 1 -Hour Rolling Average Input: greater than or equal to 9.52 subp. 14 kilowatts using 1 -hour rolling average. If the 1 -hour average total power input drops below the minimum limit, this shall be reported as a deviation. 62 of 67 EPA ID # MND006172969 April 2012 63 of 67 EPA ID 9 MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable Control 31 Electrostatic Precipitator: Operate control Minn. R. 7007.0800, Equipment equipment when the incinerator is operating subp. 14 Operating except while burning only natural gas. Requirements 32 Electrostatic Precipitator: The WESP shall Minn. R. 7007.0800, be operated with at least the minimum subp. 14 specific collection area (SCA) in service determined during the most recent particulate matter performance test showing compliance. 33 Electrostatic Precipitator: Monitor and Minn. R. 7007.0800, record the minimum SCA in service each subp. 14 day of operation. Calculate and record the 8 -hr block average WESP cleaning time. General 34 The Permittee shall determine compliance Minn. R. 7045.0542, Maintain records in the Operating with performance standards, emission subp. 6.B.(6) Operating Record Requirements limits, operating record requirements, and operating conditions set forth in this permit. The Permittee shall effectively monitor waste composition, waste feed limits, combustion parameters, control equipment operation parameters, air emissions, and flue gas flow rate. 35 The Permittee shall operate in accordance Minn. R. 7007.0800, Maintain the Operation with its most current equipment Operation subp. 14 and Maintenance Plan at and Maintenance Plan. the facility 36 The thermal treatment process and Minn. R. 7045.0542, Daily inspection recorded associated equipment must be subjected to subp. 7.13. in the operating record thorough visual inspection at least daily for leaks, spills, fugitive emissions, and signs of tampering. 37 The emergency waste feed cut off system Minn. R. 7045.0542, and associated alarms must be tested at subp. 7.C. least weekly to verify operability, unless the applicant demonstrates to the Commissioner that weekly inspections will unduly restrict or upset operations and that less frequent inspection will be adequate. Operational testing must be conducted at least monthly. 63 of 67 EPA ID 9 MND006172969 April 2012 64 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable General 38 Performance Standards: For the Rotary Minn. R. 7045.0542, Demonstrate compliance Operating Kiln, the Permittee shall at all times comply subp. 4 during the Requirements with the Performance Standards of Minn. Comprehensive R. 7045.0542, subp. 4, and other standards Performance Test listed in this Part. 39 The Permittee must perform intermediate Minn. R. 7011.7410 calculations using at least three significant figures, and may round the resultant emission levels to two significant figures to document compliance. 40 Start-up and shut -down: The Permittee shall Minn. R. 7045.0542, Maintain the approved comply with the requirements of Minn. subp. 6.C. Startup, Shutdown and R. 7045.0542, subp. 6.C. Malfunction Plan at the facility 41 Prevention of fugitive emissions: The Minn. R. 7045.0542, Monitor and record subp. 6 Permittee shall comply with the pressure in the kiln requirements of Minn. R. 7045.0542, subp. 6, item D, and Minn. R. 7011.0150. 42 Cessation of operation: The Permittee shall Minn. R. 7045.0542, comply with the requirements of Minn. subp. 6.F. R. 7045.0542, subp. 6, item F. Pursuant to Minn. Stat. § 116.85, subd. 2, if the incinerator's monitored carbon monoxide emissions exceed the permitted limit, the Permittee shall immediately either commence appropriate modifications to the Facility to ensure its ability to meet permitted requirements or commence shutdown if the modifications cannot be completed within 72 hours. Compliance with permit requirements must then be demonstrated based on additional testing. If the facility is required to shut down pursuant to Minn. Stat. § 116.85, subd. 2, the Permittee shall be allowed to resume operation only under conditions approved by the Commissioner until compliance has been demonstrated. 43 The Permittee shall operate the Rotary Kiln Minn. R. 7045.0542, in compliance with the Operating subp. 6. Requirements of this Part. 64 of 67 EPA ID # MND006172969 April 2012 65 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable General 44 All hazardous waste feed must be Minn. R. 7045.0542, Operating automatically stopped when: The operating subp. 6.E. Requirements limits specified in this permit are not met or there is a detectable failure of the incinerator process data collection system. 45 Residual materials: The Permittee shall dispose of particulates, sludges, or other wastes generated by the operation of the Facility according to solid waste rules (Minn. R. 7035.0200 to 7035.2500) and hazardous waste rules (Minn. R. ch. 7045). 46 The Permittee shall conduct performance Minn. R. 7017.2001 In conjunction with the tests on the incinerator in accordance with through 7017.2060. Comprehensive Minn. R. 7017.2001 through 7017.2060. Performance test 47 Failure to Demonstrate Compliance: Upon Minn. Stat. § 116.85, submittal of a performance test report subd. 3 demonstrating noncompliance with a permitted emission limit for the incinerator, the Permittee shall demonstrate compliance with the permitted emission limit within 60 days of the submittal. If the Permittee is unable to demonstrate compliance, the Permittee shall shut down the incinerator (Minn. Stat. § 116.85, subd. 3). Upon written notification from the MPCA that the performance test demonstrates noncompliance with an applicable operating limit, the Permittee shall conduct a retest in accordance with Minn. R. 7017.2025, subp. 4, and Minn. Stat. § 116.85. If the facility is required to shut down pursuant to Minn. Stat. § 116.85, subd. 3, the Permittee shall be allowed to resume operation pursuant to Minn. Stat. § 116.85. 48 At any time, the MPCA may obtain grab Minn. R. 7007.0800, samples of waste being charged, subp. 9.A.(4) wastewater treatment sludge, scrubber water to the plant wastewater treatment system, slag from the kiln or any other material. 65 of 67 EPA ID # MND006172969 April 2012 66 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable General 49 The Permittee shall operate all monitors Minn. R. 7045.0542, Operating required by this permit in accordance with subp. 7. Requirements Minn. R. 7017, and shall operate and maintain the following continuous monitoring equipment and devices in a manner so that the monitoring equipment and devices generate monitoring data that is consistent with the averaging times and parameters established in this permit. Unless otherwise specified below, all monitors required by this permit must be calibrated at least annually. Monitors 50 Carbon Monoxide (CO): The Permittee Minn. R. 7045.0542, shall maintain, calibrate and operate a CO subp. 7. continuous monitor meeting U.S. EPA Specification 4 (40CFR Part 60, Appendix B) and manufacturer's recommendations. The Facility may continue to operate through normal monitor downtime periods associated with maintenance activities such as calibration. 51 Oxygen (02): The Permittee shall maintain, Minn. R. 7045.0542, calibrate and operate an oxygen continuous subp. 7. monitor meeting U.S. EPA Specification 3 (40 CFR Part 60, Appendix B) and manufacturer's recommendations. The Facility may continue to operate through normal monitor downtime periods associated with maintenance activities such as calibration. 52 Monitor Breakdown: The Facility may Minn. R. 7045.0542, continue to operate for up to 30 hours per subp. 7. calendar quarter after an Automatic Waste Feed Cut Off ( AWFCO) caused by a breakdown of the 02 analyzer provided the cause of the AWFCO is diagnosed before continued operation. 53 Flue Gas Flowrate: The Permittee shall Minn. R. 7045.0542, record the flue gas flow rate using the subp. 7. method from the latest Comprehensive Performance Test. 66 of 67 EPA ID # MND006172969 April 2012 67 of 67 EPA ID # MND006172969 April 2012 Compliance Performance Demonstration Standards No. Requirement Basis If Applicable Monitors 54 Incinerator Temperature: The Permittee Minn. R. 7045.0542, shall maintain, calibrate and operate a subp. 7. continuous incinerator temperature monitor in accordance with manufacturer's specifications. The kiln exit temperature shall be measured in the mixing chamber at the kiln exit, and shall be monitored with a pyrometer or thermocouple. 55 Wet Electrostatic Precipitator (WESP) Minn. R. 7045.0542, Power: The Permittee shall maintain, subp. 7. calibrate and operate a continuous power monitor on the WESP in accordance with manufacturer's specification. 56 Flow rate of fuel oil and pumpable waste: Minn. R. 7045.0542, The Permittee shall maintain, calibrate and subp. 7. operate continuous monitors to measure the flow rate of fuel oil and pumpable waste in accordance with manufacturer's specifications. 57 Pressure Monitors: The Permittee shall Minn. R. 7045.0542, maintain, calibrate and operate continuous subp. 7. monitors to measure pressure drops within the combustion system in accordance with manufacturer's specifications. 58 The Permittee shall maintain, calibrate and Minn. R. 7045.0542, operate water pressure monitors and water subp. 7. flowrate monitors for all control equipment listed in this Part in accordance with manufacturer's specifications. Performance 59 If the Permittee requests a modification that Minn. R. 7001.0170 Testing is likely to affect the ability of the facility to meet applicable performance standards or comply with existing operating parameters, the Commissioner may require the Permittee to conduct a trial burn to demonstrate compliance with Minn. R. 7045.0542, subp. 4. and/or subp. 6., following the requirements of Minn. R. 7001.0700, subp. 11. 67 of 67 EPA ID # MND006172969 April 2012 APPENDICES APPENDIX I - FACILITY MAPS B > 6 5 4 ] 2 1 j G / G ,aa 60 47 145 _ H ° Hous / U l 75 i t j ° � . c � —`��` slNe� — Tom•^ eoao■ao� :� M 13 CI ; Mill t ` 1 i i •f I l _ ,o .. Md _ f J I re._ • �_ f � � • 1 00 i l> 2 IJ li W q U U] Q APPENDIX II - LIST OF HAZARDOUS WASTE STORED OR TREATED WASTE NUMBERS D001 F001 P017 P070 P127 UO28 U076 U123 U169 U219 U385 D002 F002 P018 P071 P128 UO29 U077 U124 U170 U220 U386 D003 F003 P020 P072 P185 UO30 U078 U125 U171 U221 U387 D004 F004 P021 P073 P188 UO31 U079 U126 U172 U222 U389 D005 F005 P022 P074 P189 UO32 U080 U127 U173 U223 U390 D006 F006 P023 P075 P190 UO33 U081 U128 U174 U225 U391 D007 F007 P024 P076 P191 UO34 U082 U129 U176 U226 U392 D008 F008 P026 P077 P192 UO35 U083 U130 U177 U227 U393 D009 F009 P027 P078 P194 UO36 U084 U131 U178 U228 U394 D010 F010 P028 P081 P196 UO37 U085 U132 U179 U234 U395 D011 F011 P029 P082 P197 UO38 U086 U133 U180 U235 U396 D012 F012 P030 P084 P198 UO39 U087 U134 U181 U236 U400 D013 F019 P031 P085 P199 U041 U088 U135 U182 U237 U401 D014 F020 P033 P087 P201 U042 U089 U136 U183 U238 U402 D015 F021 P034 P088 P202 U043 U090 U137 U184 U239 U403 D016 F022 P036 P089 P203 U044 U091 U138 U185 U240 U404 D017 F023 P037 P092 P204 U045 U092 U140 U186 U243 U407 D018 F024 P038 P093 P205 U046 U093 U141 U187 U244 U408 D019 F025 P039 P094 U047 U094 U142 U188 U246 U409 D020 F026 PO40 P095 U001 U048 U095 U143 U189 U247 U410 D021 F027 PO41 P096 U002 U049 U096 U144 U190 U248 U411 D022 F028 PO42 P097 U003 U050 U097 U145 U191 U249 D023 F039 PO43 P098 U004 U051 U098 U146 U192 U271 D024 PO44 P099 U005 U052 U099 U147 U193 U277 D025 MN0l PO45 P101 U006 U053 U101 U148 U194 U278 D026 NW02 PO46 P102 U007 U055 U102 U149 U196 U279 D027 MNO3 PO47 P103 U008 U056 U103 U150 U197 U280 D028 MN04 PO48 P104 U009 U057 U105 U151 U200 U328 D029 PO49 P105 U010 U058 U106 U152 U201 U353 D030 P001 P050 P106 U011 U059 U107 U153 U202 U359 D031 P002 P051 P108 U012 U060 U108 U154 U203 U364 D032 P003 P054 P109 U014 U061 U109 U155 U204 U365 D033 P004 P056 P110 U015 U062 U110 U156 U205 U366 D034 P005 P057 P111 U016 U063 U111 U157 U206 U367 D035 P006 P058 P112 U017 U064 U112 U158 U207 U372 D036 P007 P059 P113 U018 U066 U113 U159 U208 U373 D037 P008 P060 P114 U019 U067 U114 U160 U209 U375 D038 P009 P062 P115 UO20 U068 U115 U161 U210 U376 D039 P010 P063 P116 UO21 U069 U116 U162 U211 U377 D040 P011 P064 P118 UO22 U070 U117 U163 U213 U378 D041 P012 P065 P119 UO23 U071 U118 U164 U214 U379 D042 P013 P066 P120 UO24 U072 U119 U165 U215 U381 D043 P014 P067 P121 UO25 U073 U120 U166 U216 U382 P015 P068 P122 UO26 U074 U121 U167 U217 U383 P016 P069 P123 UO27 I U075 I U122 I U168 I U218 IU384 LIST OF APPROVED WASTES Waste No. Description of Hazardous Waste D001 Solid waste that exhibits the characteristic of ignitability, but is not listed as a hazardous waste D002 Solid waste that exhibits the characteristic of corrosivity, but is not listed as a hazardous waste. D003 Solid waste that exhibits the characteristic of reactivity, but is not listed as a hazardous waste. The following solid wastes exhibiting the characteristic of TCLP for: Waste No. Description of Hazardous Waste D004 Arsenic at 5.0 mg /l or more D005 Barium at 100 mg /l or more D006 Cadmium at 1.0 mg /l or more D007 Chromium at 5.0 mg /l or more D008 Lead at 5.0 mg /l or more D009 Mercury at 0.2 mg /l or more DO 10 Selenium at 1.0 mg /l or more DO11 Silver at 5.0 mg /l or more D012 Endrin at 0.02 mg /l or greater D013 Lindane at 0.40 mg /l or greater D014 Methoxychlor at 10.0 mg /l or greater D015 Toxaphene at 0.50 mg /l or greater D016 2,4 -D at 10.0 mg /l or greater D017 2,4,5 -TP (silvex) at 1.0 mg /l or greater D018 Benzene at 0.5 mg /l or greater D019 Carbon tetrachloride at 0.5 mg /l or greater D020 Chlordane at 0.03 mg /l or greater D021 Chlorobenzene at 100.0 mg /l or greater D022 Chloroform at 6.0 mg /l or greater D023 O- Cresol at 200 mg /l or greater D024 M- Cresol at 200 mg /l or greater D025 P- Cresol at 200 mg /l or greater D026 Cresol at 200 mg /l or greater D027 1,4- dichlorobenzene at 7.5 mg /l or greater D028 1,2- dichlorobenzene at 0.5 mg /l or greater D029 1,1- dichloroethylene at 0.7 mg /l or greater 1 Waste No. Description of Hazardous Waste D030 2,4- dinitrotoluene at 0.13 mg /l or greater D031 Heptachlor (and its epoxide) at 0.008 mg /l or greater D032 Hexachlorobenzene at 0.13 mg /l or greater D033 Hexachlorobenzene at 0.13 mg/l or greater D034 Hexachlroethane at 3.0 mg /l or greater D035 Methyl ethyl ketone at 200 mg /l or greater D036 Nitrobenzene at 2.0 mg /l or greater D037 Pentachlorphenol at 100 mg /l or greater D038 Pyridine at 5.0 mg/l or greater D039 tetrachlroethylene at 0.7 mg /l or greater D040 Trichloroethylene at 0.5 mg /l or greater D041 2,4,5 - trichlorophenol at 400 mg /l or greater D042 2,4,6 - trichloroephenol at 2.0 mg /l or greater D043 Vinyl chloride at 0.2 mg /l or greater F001 The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 - trichloroethane, carbon tetrachloride, chlorinated fluorocarbons, spent solvent mixtures /blends used in degreasing, andstill bottom from the recovery of these spent solvents and spent solvent mixtures. F002 The following spent halogenated solvents: tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1 - trichloroethane, chlorobenzene, 1, 1, 2- trichloro - 1,2,2 - trifluoroethane, orthodichlorobenzene, trichlorofluoromethane, 1,1,2 - trichloroethane, spent solvent mixtures and blends, and the still bottoms from the recovery of these spent solvents and spent solvent mixtures. F003 The following spent non - halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n -buryl alcohol, cyclohexanone, methanol, spent solvent mixtures and blends, and the still bottoms from the recovery of these spent solvents and spent solvent mixtures. F004 The following spent non - halogenated solvents: cresols and cresylic acid, nitrobenzene, spent solvent mixtures and blends, and still bottoms from the recovery of these spent solvents and spent solvent mixtures. F005 The following spent non - halogenated solvents: toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2- ethoxyethanol, 2- nitropropane, spent solvent mixtures and blends, and the still bottoms from the recovery of these spent solvents and spent solvent mixtures. F006 Wastewater treatment sludges from electroplating operations except from the following processes: (1) Sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or zinc - aluminum plating on carbon steel; (5) cleaning /stripping associated with tin, zinc and aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum. 2 Waste No. Description of Hazardous Waste F007 Spent cyanide plating bath solutions from electroplating operations. F008 Plating bath residues from the bottom of plating baths from electroplating operations where cyanides are used in the process. F009 Spent stripping and cleaning bath solutions from electroplating operations where cyanides are used in the process. FO10 Quenching bath residues from oil baths from metal heat treating operations where cyanides are used in the process. FO11 Spent cyanide solutions from salt bath pot cleaning from metal heat treating operations. F012 Quenching waste water treatment sludges from metal heat treating operations where cyanides are used in the process. F019 Wastewater treatment sludges from the chemical conversion coating of aluminum except from zirconium phosphating in aluminum can washing when such phosphating is an exclusive conversion coating process. F024 Wastes, including but not limited to, distillation residues, heavy ends, tars, and reactor clean -out wastes from the production of chlorinated aliphatic hydrocarbons. F025 Condensed light ends, spent filters and filter aids, and spent desiccant wastes from the production of certain chlorinated aliphatic hydrocarbons, be free radical catalyzed processes. These chlorinated aliphatic hydrocarbons are those having carbon chain lengths ranging from one to and including five, with varying amounts and positions of chlorine substitution. F032 Wastewaters, process residuals, preservative drippage and spent formulations from wood preserving processes generated at plants that currently use or have previously used chlorophenolic formulations (except potentially cross - contaminated wastes that have had the F032 waste code deleted in accordance with Section 721.135 and where the generator does not resume or initiate use of chlorophenolic formulations). This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote or pentachlorophenol. F034 Wastewaters, process residuals, preservative drippage and spent formulations from wood preserving processes generated at plants that use creosote formulations. This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote or pentachlorophenol. F035 Wastewaters, process residuals, preservative drippage and spent formulations from wood preserving processes generated at plants that use inorganic preservatives containing arsenic or chromium. This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote or pentachlorophenol. Waste No. Description of Hazardous Waste F037 Petroleum refinery primary oil /water /solids separation sludge. F038 Petroleum refinery secondary (emulsified) oil /water /solids separation sludge. F039 Leachate resulting from the storage, treatment or disposal of hazardous wastes. Discarded Commercial Chemical Products, Off - Specification Species, Container Residues, and Spill Residues Thereof: Waste No. Description of Hazardous Waste P00l Warfarin, when present at concentrations greater than 0.3 %. P002 1- Acetyl -2- thiourea P003 Acrolein P004 Aldrin P005 Allyl alcohol P007 5- (Aminomethyl)- 3- isoxazolol P008 4- Aminopyridine P009 Ammonium picrate Polo Arsenic acid Poll Arsenic pentoxide P012 Arsenic trioxide P013 Barium cyanide P014 Benzenethiol P015 Beryllium dust P016 Bis- chloromethyl) ether P017 Bromoacetone P018 Brucine P020 Dinoseb P021 Calcium cyanide P022 Carbon bisulfide P023 Chloroacetaldehyde P024 p- Chloroaniline P026 1- (o- Chlorophenyl) thiourea P027 3- Chloropropionitrile P028 Benzyl chloride P029 Copper cyanides P030 Cyanides (soluble cyanide salts) not elsewhere specified. P031 Cyanogen P033 Cyanogen chloride P034 4,6- Dinitro- o- cyclohexylphenol P036 Dichlorophenylarsine P037 Dieldrin P038 Diethylarsine P039 Disulfoton 4 Waste No. Description of Hazardous Waste PO40 O,O- Diethyl O- pyrazinyl phosphoro - thioate PO41 Diethyl -p- nitrophenyl phosphate PO42 1,2- Benzenediol, 4 -[1- hydroxy -2- (methyl - mamino)ethyl] PO43 Diisopropyl fluorophosphate PO44 Dimethoate PO45 Thiofanox PO46 Ethanamine, 1,10dimethyl-2-phenyl- PO47 4,6- Dinitro -o- cresol and salts PO48 2,4- Dinitrophenol PO49 2,4- Dithiobiuret P050 Endosulfan P051 Endrin P054 Ethylenimine P056 Fluorine P057 Fluoroacetamide P058 Fluoroacetic acid, sodium salt P059 Heptachlor P060 Hexachlorohexahydro -endo, endo - dimethanonaphthalene P062 Hexaethyl tetraphosphate P063 Hydrogen cyanide P064 Methyl Isocyanate P065 Fulminic acid, mercury(2 +)salt P066 Methomyl P067 2- Methylaziridine P068 Methyl hydrazine P069 2- Methyllactonitrile P070 Aldicarb P071 Methyl parathion P072 alpha - Naphthylthiourea P073 Nickel carbonyl P074 Nickel cyanide P075 Nicotine and salts P076 Nitric oxide P077 p- Nitroaniline P078 Nitrogen dioxide P081 Nitroglycerine P082 N- Nitrosodimethylamine P084 N- Nitrosomethylvinylamine P085 Octamethylpyrophosphoramide P087 Osmium oxide P088 Endothall P089 Parathion 5 Waste No. Description of Hazardous Waste P092 Phenylmercuric acetate P093 N- Phenylthiourea P094 Phorate P095 Phosgene P096 Phosphine P097 Pamphur P098 Potassium cyanide P099 Potassium silver cyanide P101 Propanenitrile P102 Propargyl alcohol P103 Selenourea P104 Silver cyanide P105 Sodium azide P106 Sodium cyanide P108 Strychnine and salts P109 Tetraethyldithiopyrophosphate Pilo Tetraethyl lead P111 Tetraethylpyrophosphate PI 12 Tetranitromethane P113 Thallic oxide P114 Thallium(1) selenide P115 Thallium(1) sulfate P116 Thiosemicarbazide P118 Trichloromethanethiol P119 Vanadic acid, ammonium salt P120 Vanadium pentoxide P121 Zinc cyanide P122 Zinc Phosphide ZN3P2 P123 Toxaphene P127 7- Benzofuranol, 2,3- dihydro -2,2- dimethyl -, methylcarbamate P128 Phenol, 4- (dimethylamino) -3,5- dimethyl -, methylcarbamate (ester) P185 1 ,3- Dithiolane -2- carboxaldehyde, 2,4- dimethyl -. 0- [(methylamino)carbonyl] oxime P188 Benzoic acid, 2- hydroxy, compound with (3aS -cis)- 1,2,3,3 a,8,8a- hexahydro- 1,3a,8- trimethylpyrrolo [2,3- b]indol -5 -yl methylcarbamate ester (1:1) P189 Carbamic acid, [(dibutylamino)thos]methyl -, 2, 3- dihydro -2,2- dimethyl- 7- benzofuranyl ester Manganese dimethyldithiocarbamate 0 Waste No. Description of Hazardous Waste P190 Carbamic acid, methyl -, 3- methylphenyl ester P191 Carbamic acid, dimethyl -, 1- [dimethylamino carbonyl] -5- methyl- lH- pyrazol -3 -yl ester P192 Carbamic acid, dimethyl -, 3- methyl -l- (1- methylethyl)- 1Hpyrazol -5 -yl ester P194 Ethanimidothioc acid, 2 -( dimethylamino) -N- [(methylamino) carbonyl)oxy]- 2 -oxo- , methyl ester P196 Manganese, bis( dimethylcarbamodithioato- S,S')- P197 Methanimidamide, N,N- dimethyl -Ni- [2- methyl -4 [[(methylamino)carbony]phenyl]- P198 Methanimidamide, NN- dimethyl- Ni -[3- [(methylamino) carbonyl]oxylphenyl] -, monohydrochloride P199 Phenol, (3,5- dimethyl -4- (methylthio) -, methylcarbamate P201 Phenol, 3- methyl -5 -(1- methylethyl) -, methyl carbamate P202 Phenol, 3 -(1- methylethyl) -, methyl carbamate 3- 1sopropylphenyl N- meethylcarbamate orm- Cumenyl methylcarbamate P203 Propanal, 2- methyl -2- (methysulfonyl) -, 0- [(methylamino)carbonyl] oxime P204 Pyrrolo[2,3- b]indol -5 -01, 1,2,3,3a,8,8a- hexahydro -1, 3a,8- trimethyl -, methylcarbamate (ester), 3aS -cis)- P205 Zinc, bis( dimethylcarbamodithioato- S,Si) -, (T -4)- Commercial Chemical Products, Manufacturing Chemical Intermediates, or Off - Specification Commercial Chemical Products: Waste No. Description of Hazardous Waste U001 Acetaldehyde U002 Acetone U003 Acetonitrile U004 Acetophenone U005 2- Acetylaminofluorene U007 Acrylamide U008 Acrylic acid U009 Acrylonitrile U010 Mitomycin C U011 Amitrole U012 Aniline U014 Auramine U015 Azaserine U016 Benz(c)acridine U017 Benzal chloride U018 Benz(a)anthracene 7 U019 Benzene Waste No. Description of Hazardous Waste U120 Fluoranthene UO21 Benzidine UO22 Benzo(a)pyrene U123 Formic Acid UO24 Bis(2- chloroethyoxy) methane UO25 Dichloroethyl ether UO26 Chloronaphazine UO27 Bis(2- chloroisopropyl) ether UO28 Bis(2- ethylhexyl) phthalate UO29 Bethyl bromide UO30 Benzene, 1- bromo -4- phenoxy- UO31 N -Butyl alcohol UO32 Calcium chromate UO34 Chloral UO35 Chlorambucil UO36 Chlordane, technical UO37 Chlorobenzene UO38 Ethyl4,4'- dichlorobenzilate UO39 4- Chloro -m- cresol U041 1- Chloro -2,3- epoxypropane U042 2- Chloroethyl vinyl ether U043 Vinyl chloride U044 Chloroform U045 Methyl chloride U046 Chloromethyl methyl ether U047 beta - Chloronaphthalene U048 o- Chlorophenol U049 Benzenamine, 4- chloro- 2- methyl- U050 Chrysene U051 Creosote U052 Cresols U053 Crotonaldehyde U055 Cumene U056 Cyclohexane U057 Cyclohexanone U058 Cyclophosphamide U059 Daunomycin U060 DDD U061 DDT U062 Diallate U063 Dibenz[a,h]anthracene U064 Dibenz[a,i]pyrene 8 Waste No. Description of Hazardous Waste U066 1,2 -D ibromo -e- chloropropane U067 Ethylene dibromide U068 Methylene bromide U069 Dibutyl phthalate U070 o- Dichlorobenzene U071 m- Dichlorobenzene U072 p- Dichlorobenzene U073 3- 3'Dichlorobenzidine U074 1,4 -D ichlo ro -2- butene U075 Dichlorodifluoromethane U076 Ethylidene dichloride U077 Ethylene dichloride U078 1,1- Dichloroethylene U079 1,2- Dichloro ethylene U080 Methylene chloride U081 2,4- Dichlorophenol U082 2,6- Dichlorophenol U083 1,2- Dichloropropane U084 1,3- Dichloropropane U085 1,2:3,4- Diepoxybutane U086 NN- Diethylhydrazine U087 o,o- Diethyl -S- methyl - dithiophosphate U088 Diethyl phthalate U089 Diethylstilbestrol U090 Dihydrosafrole U091 3,3'- Dimethoxybenzidine U092 Dimethylamine U093 Dimethylaminoazobenzene U094 7,12 - Dimethylbenz[a]anthracene U095 3,3'- Dimethylbenzidine U096 2,2- Dimethylbenzylhydroperoxide U097 Dimethylcarbamoyl chloride U098 1,1- Dimethylhydrazine U099 1,2 -D imethylhydrazine U101 2,4 -D imethylphenol U102 Dimethyl phthalate U103 Dimethyl sulfate U105 2,4- Dinitrotoluene U106 2,6- Dinitrotoluene U107 Di -n -octyl phthalate U108 1,4- Dioxane U109 1,2- Diphenylhydrazine Waste No. Description of Hazardous Waste 9 U110 Dipropylamine Ulll Di -N- propylnitrosamine Ul 12 Ethyl acetate U113 Ethyl acrylate U114 Ethylenebis(dithiocarbamic acid), salts and esters U115 Ethylene oxide U116 Ethylene thiourea U117 Ethyl ether U118 Ethyl methacrylate U119 Ethyl methanseulfonate U120 Fluoranthene U121 Metane, trichlorofluoro- U122 Formaldehyde U123 Formic acid U124 Furan U125 Furfural U126 Glycidylaldehyde U127 Hexachlorobenzene U128 Hexachlorobutadene U129 Lindane U130 Hexachlorcyclopentadene U131 Hexachloroethane U132 Hexachlorophene U133 Hydrazine U134 Hydrogen fluoride U135 Hydrogen sulfide U136 Cacodylic acid U 13 7 Indeno [ 1, 2, 3 -cd] pyrene U138 Iodomethane U140 Isobutyl alcohol U141 Isosafrole U142 Kepone U143 Lasiocarpine U144 Lead acetate U145 Lead phosphate U146 Lead subacetate U147 Maleic anhydride U148 Maleic hydrazide U149 Malononitrile 10 Waste No. Description of Hazardous Waste U150 Melphalan U151 Mercury U152 Methacrylonitrile U153 Methanethiol U154 Methanol U155 Methapyrilene(T) U156 Methyl chlorocarbonate U157 3- Methylchlolanthrene U158 4, 4 '- Methylenebis(2- chloroaniline) U159 Methyl ethyl ketone U160 Methyl ethyl ketone peroxide U161 Methyl isobutyl ketone U162 Methyl methacrylate U163 N- methyl - N'nitro -N- nitrosoquanidine U164 Methylthiouracil U165 Napthalene U 16 6 1,4- Naphthalenedione U167 1- Naphthylamine U168 2- Naphthylamine U169 Nitrobenzene U170 p- Nitrophenol U171 2- Nitropropane U172 N- Nitrosodi -n- butylamine U173 N- Nitrosodiethanolamine U174 N- Nitrosodiethylamine U176 N- Nitroso -N- ethylurea U177 N- Nitroso -N- methylurea U178 N- Nitroso -N- methylurethane U179 N- Nitrosopiperidine U180 Nitrosopyrrolidine U 181 5 - Nitro -o -to lui dine U182 Paraldehyde U183 Pentachlorobenzene U184 Pentachloroethane U185 Pentachloronitrobenzene U186 1,3- Pentadiene U187 Phenacetin U188 Phenol U189 Phosphorus sulfide 11 Waste No. Description of Hazardous Waste U190 Phthalic anhydride U191 Pyridine, 2- methyl- U192 Pronamide U193 1,3- Propane sultone U194 1- Propanamine U196 Pyridine U197 p- Benzoquinon U200 Reserpine U201 Resorcinol U202 Saccharin and salts U203 Safrole U204 Selenium dioxide U205 Selenium sulfide U206 Streptozotocin U207 1,2,4,5- Tetrachlorobenzene U208 1, 1, 1,2,-Tetrachloroethane U209 1,1,2,2,- Tetrachloroethane U210 Tetrachloroethylene U211 Carbon tetrachloride U213 Tetrahydrofuran U214 Thallium(1) acetate U215 Thallium(1) carbonate U216 Thallium(1) chloride U217 Thallium(1) nitrate U218 Thioacetamide U219 Thiourea U220 Toluene U221 Toluenediamine U222 o- Toluidine hydrochloride U223 Toluene diisocyanate U225 Bromoform U226 1, 1, 1 -Trichloroethane U227 1,1,2- Trichloroethane U228 Trichloroethene U234 1,3,5- Trinitrobenzene U235 Tris(2,3- dibromopropyl) phosphate U236 Trypan blue U237 Uracil mustard U238 Ethyl carbarmate (urethan) U239 Xylene 12 Waste No. Description of Hazardous Waste U240 2,3 -D, salts and esters U243 Hexachloropropene U244 Thiram U246 Bromine cyanide U247 Methoxychlor U248 Warfarin, when present at concentrations of 0.3% or less U249 Zinc phosphide, when present at concentrations of 10% or less U271 Carbamic acid, [1- [(butylamino )carbonyl]- 1Hbenzimidazol- 2-yl]-, methyl ester U278 1,3- Benzodioxol -4 -ol, 2,2- dimethyl -, methyl carbamate U279 1- Naphthalenol, methylcarbamate U280 Carbamic acid, (3- chlorophenyl) -, 4- chloro -2- butynyl ester U328 o- Toluidine U353 p- Toluidine U359 Ethylene glycol monoethyl ether U364 1,3- Benzodioxol -4 -ol, 2,2- dimethyl -, U367 7- Benzofuranol, 2,3- dihydro- 2,2- dimethyl- U372 Carbamic acid, 1 H- benzimidazol -2 -yl, methyl ester U373 Carbamic acid, phenyi -, 1 - methylethyl ester U387 Carbamothioic acid, dipropyl -, S- (phenylmethyl) ester U389 Carbamothioic acid, bis(1-methylethyl)- S- (2,3,3 - trichloro -2- propenyl) ester U394 Ethanimidothioic acid, 2 -( dimethylamino ) -N- hydroxy- 2 -oxo -, methyl ester U395 Ethanol, 2,2'- oxybis -, discarbamate U404 Ethanamine, N,N- diethylILD098642424 U408 2,4,6 - Tribromophenol U409 Carbamic acid, [1,2- phenylenebis (iminocarbonothioyl)]bis, dimethyl ester U410 Ethanimidothioc acid, N,Ni- [thiobis(methylimimo )carbonyloxy]bis- ,dimethyl ester U411 Phenol, 2 -(1- methylethoxy) -, methylcarbamate 13 3M Cott age Grove Center Certified Mail December 18 2009 PO Box 33131 St. Paul, MN 55133 3131 651 =458 2000 Mr, Greg Kvaal Hazardous Waste Unit Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 -4194 Subject: RCRA Permit Renewal Application 3M Cottage Grove Corporate Incinerator (ID 12300025) Dear Greg; At the request of the MPCA 3M is submitting to you via e-mail an application for the renewal of the permit for the 3M incinerator located at 11706 Innovation Road, Cottage Grove, MN EPA ID number 000172969. Enclosed with this letter is the application fee In the amount of $106,670, and a copy of the original signed Certification Statement for the application. If you have any questions regarding the permit renewal, please contact 'me by email at tg6shenmacherCc mn rrl.cam or by phone at (651) 788 - 2643. Sincerely, Thomas G. Ashenmacher Enclosure(s) - Check for Application Fee Certification Statement 3M Cottage Grove Center PO Box 3,3131 St. Paul, N1N 55133 3131 6.51458 2000 By Courier 12/18/2009 r - 6. Lee Sal Support and Permits Section Management Branch Pesticides and Toxics Division States Environmental Protection Agency 77 West Jackson Boulevard Chicago, IL 60604 -3590 Subject: Permit Renewal Application 3M Cottage Grove Corporate Incinerator (ID 12300026) Dear Mr, Lee' Enclosed please find' an application for a Hazardous Waste Permit renewal for the 3M Cottage Grove Corporate Incinerator EPA ID Number' 006172969. Please note that this application only addresses hazardous waste issues such as general facility requirements storage; limits, closure and financial assurance. It does not include detailed information on the incinerator design, operating parameters, or emissions, these are addressed in the facilities Title V air permit; This application has also been submitted to Mr,. Greg Kvaal at the Minnesota Pollution Control Agency. If you have any questions regarding this permit amendment application and transmittal letter, please contact me by email at tgashenmacherPmmm.com or by phone at (651) 768- 2643. Sincerely, t .tl A ot), Thomas G. Ashenmacher Enclosures Cc: Greg Kvaal — Minnesota Pollution Control Agency 3M Section _U 12/18109 CERITIFCATION STATEMENT I certify under penalty of law that this under my direction or supervision in acc qualified personnel properly gathered at on my inquiry of the person of person: t and all attachments were prepare vith a system designed to - assure th ted the information submitted. Bao �re y IVspolls I a ar kI s an g a �nIWPIIIGLIWI LIIV 11.1 W, IILALIVII VMM111144VM IV/ best of my knowledge and belief, true, accurate, and complete (Minn, R. 700110070). am aware there are significant penal #ies for submitting false information, including th, possibility of fine and imprisonment (Minn. R. 7001.0540). Garner Gary operations .Manager Last Name First Name Title 11706 Innovation_ Road Mailing Address Cottage Grove MN 55016 City , State Zip Code 3M Section A 12/18//09 SECTION A GENERAL FACILITY DESCRIPTION A.1 INTRODUCTION Multiple 3M divisions operate manufacturing facilities at the 3M Cottage Grove Center located in Cottage Grove, Minnesota, 15 miles south of St. Paul. The plant is owned and operated by: 3M Company 3M Center - General Offices 1 -94 and McKnight Road St. Paul, Minnesota 55144 The address of the Cottage Grove facility is: 3M Cottage Grove Center 10746 Innovation Road Cottage Grove, Minnesota 55016 3M Cottage Grove Center is a diversified manufacturing facility that produces a wide variety of products including adhesives, tapes, resins, chemicals, polymeric films and extrusions, abrasive products, and hollow glass bead extenders. Also located on the plant site is the 3M Corporate Incinerator, including a rotary kiln, air pollution control equipment, container storage areas and tank storage. These facilities provide treatment and storage for business - related wastes generated by 3M's operating divisions throughout North America and from non - 3M sources within the United States. 3M Cottage Grove Center is therefore classified as both a generator and a treatment /storage facility in accordance with the 1976 Resource Conservation & Recovery Act. No waste disposal is conducted on the site. Although the facility will process waste from non -3M sources, 3M is prohibited from accepting payment or other compensation for burning wastes generated by non -3M sources. A.2 THE 3M CORPORATE INCINERATION FACILITY The 3M Cottage Grove Center incineration system was constructed in 1971. Subsequent additions and improvements at the facility have kept pace with technological advancements over the years, maintaining the incinerator system's state -of- the -art status and ensuring continued conformance with government regulations. Significant upgrades have included: 1982 - Wet Electrostatic Precipitator (WESP) - Improved air emission control 1988 - Air pollution control retrofit - Upgrades to the scrubbing system and added a computerized process control system. A -1 3M Section A 12/18//09 1989 - Bar coding system - Provided an incinerator -wide computerized tracking system, accounting for waste from receipt through disposal. 1990 - Tanker unloading station - Made handling of bulk liquids more efficient. 1990 - Sludge feed pump - Provided better handling and control of pourable materials. 1990 - Continuous emission monitors - Keeps a continuous record of stack gases. 1996 - Air pollution control - Upgrades to the scrubbing system with an enhanced venturi scrubber. 1999 - Air pollution control - Upgrades to the scrubbing system with implementation of a subcooler and the addition of a wet electro- static precipitator. 2000 — Replacement kiln, Bldg. 145 sludge room, and Komar shredder 2003 — Closure of original kiln and associated equipment 2003 — Conversion of Tank #1 from fuel oil to hazardous waste; and installation of an emissions control flare 2004 —New tank farm 2009 — WESP plate replacement The 3M Corporate Incinerator handles the following types of materials: • Containerized solids • Containerized sludges • Containerized liquids • Bulk solids • Bulk liquids • Containerized gases. A complete listing of hazardous waste stored and treated is found in Section B, Table B -1 of this permit application. The waste handling facility, which includes the incinerator, receives materials from on -site and off -site. These materials may be stored in tanks or container storage areas prior to treatment. Physical treatment, such as shredding, phase separation, or blending, may be performed prior to feeding materials to the incinerator. The waste handling facility also serves as a staging center for the collection of wastes that are sent to commercial Treatment, Storage, and Disposal Facilities (TSDF). The facility currently consists of container and bulk unloading storage areas in Buildings 77 and 136; container storage areas in Buildings 60, 47 and 145; trailer container storage areas and bulk storage tanks. Hazardous waste is stored in the following tanks: • One 10,000 gallon decant tank - Tank 20; • Eight 18,360 gallon tanks - Tanks 21 -28, • One 200,000 gallon - Tank 1, and; • Two 2,150 gallon sludge process /storage tanks located in Building 145. A -2 3M Section A 12/18//09 The main units are a rotary kiln incinerator; air pollution control equipment, an ash management system, and a 90 -day storage area for ash (Building 181). Detailed information on air emissions from the incinerator process, and the air pollution control equipment, is included in the facility's Title V Permit Application, updated in 2009, and is not part of this permit application.. A.3 WASTE RECEIVING AND HANDLING A.3.1 Containerized Materials Receiving, Storage, and Handling Containerized materials are shipped to the incineration facility by truck. Containers are primarily 55- gallon steel drums. However, wastes are also received in other types of containers, including various sizes of steel drums, totes, plastic and fiber drums, pails, boxes, and portable tanks. The types of containerized wastes that may be received include solids, pumpable sludges, organic liquids, aqueous liquids, and gaseous wastes. Shipments of waste may be staged in storage Lot C or the south half of Lot A for no longer than 10 days prior to receipt. Containerized materials are received at Buildings 47 and 60. A hand held radio frequency terminal with a bar code scanner is used to enter information from the container labels into the facility computer system. This data is verified with the information in the waste stream profile and on the manifest. Any discrepancies are resolved with the waste generator. A unique load ID bar code is affixed to each container to facilitate container tracking and proper disposal. Containerized materials may be staged for either immediate treatment /disposal or sorted and loaded back onto trailers for storage in a permitted trailer storage area. A detailed description of container storage can be found in Section S1 of this permit application. When containers of liquid are processed, they are typically transferred to the pump room in Building 47, the sludge processing room in Building 145 or the direct burn room in Building 145. From the pump room in Building 47, pumpable materials can be transferred directly to the kiln, to the 10,000 - gallon decant tank, or one of the waste storage tanks. In the sludge processing room in Building 145, containers are emptied into a sludge hopper that drains into a 2,150 gallon batch tank. The direct burn room in Building 145 is designed for transferring the liquid or gas contents of a container directly to a waste lance. Containerized liquids or gases may also be transferred directly to a waste lance through the direct burn line originating at Building 77. When containers of solids are, processed they are staged and prepared for processing on the pak feeder or Komar shredder. The drum proceeds to a series of conveyors that ultimately deliver its contents to the kiln either through the feed chute, drum feeder, or the Komar shredder drum feeder. Palletized materials are transferred by a lift and pallet conveyor to the Komar shredder pallet feed chamber. A -3 3M Section A 12/18//09 A.3.2 Bulk Liquids Receiving, Storage, and Handling Manifests for shipments of bulk liquid waste that are received at the facility, are reviewed, and the waste information is entered into the computerized waste inventory system. A compatibility check of the waste against the wastes stored in the bulk tanks is completed and if there are no compatibility issues, the bulk liquids are unloaded at the Tanker Unloading building 136. Liquid wastes are pumped into one of the waste tanks listed in Section A.2 Bulk liquids can also be transferred from Building 77 directly to a waste lance via the direct burn line. Tanker trucks may be stored in trailer storage lot C, the south (concrete) half of Lot A, or the docks at Buildings 77 or 136. (Refer to Appendix A.) A detailed description of tank storage system is found in Section S2 of this application. A.3.3 Bulk Solids Receiving, Storage, and Handling Bulk solids, consisting primarily of soils and debris, are handled as special projects requiring MPCA approval before unloading to the containment Building181. Bulk material would be delivered by dump truck or roll -off box, unloaded inside the containment building, and repackaged for processing in the kiln as containerized solids. A.4 WASTE SHIPPED OFF SITE The following waste materials may be received and staged prior to shipment off -site for reclamation, treatment, and /or disposal: • Containerized solids, liquids, and sludges • Bulk liquids • Compressed gases. • Articles /Electronics The following materials are generated at the incinerator and are shipped to off -site TSDF for disposal: • Bulk kiln slag /ash • Air pollution control sludge. Empty steel drums are also sent off -site for reconditioning and reclamation. A.5 PROCESS EQUIPMENT A schematic drawing of the 3M Corporate Incinerator and a Facility layout drawing are presented in Appendix A. The major process areas in the facility are: • Waste feed systems • Combustion system • Ash handling system • Air pollution control system A -4 3M Section A 12/18//09 • Wastewater treatment system A brief description of the characteristics and functions of the process equipment in each area is presented below. A more detailed description is in Section S4 of this application. A.6 WASTE FEED SYSTEMS The following access points are available to feed materials into the incinerator combustion system: • Kiln Feed Chute • Kiln Burner (2 total: 1 fuel oil and 1 waste)) • Kiln Waste Lances ( 3) • Kiln Sludge Lance (1) • Secondary Combustion Chamber Lance (1) A.6.1 Kiln Feed Chute Containers of waste are fed through the kiln feed chute into the rotary kiln by either the drum feeder system or the Komar shredder. The feed chute connects to the kiln through the kiln feed face. Drummed wastes are dumped into the feed chute from the drum feeder by means of a drum dumping device. Depending on the properties of the waste, the entire drum may be fed to the kiln, or dumped with the drum recovered and shipped off -site to be reconditioned. Blended wastes from the Komar shredder are extruded in the upper portion of the feed chute through a feed tube. A system of conveyors called the pak feeder, moves drummed waste from the drum feeding staging area through an inspection station to the drum feeder. Drums may also be delivered individually or in palletized groups to the Komar shredder. The Komar shredder shreds multiple containers of wastes to create a batch of blended waste that is extruded into the feed chute. A.6.2 Kiln Burner The kiln has a single burner equipped with a gas ring and two nozzles. The kiln burner is located in the kiln frontwall. The kiln burner uses No. 2 fuel oil or natural gas to provide heat for the controlled start -up of the incinerator, and fuel oil, natural gas, or waste solvents to maintain temperature in the kiln. A.6.3 Kiln Waste Lances Three (3) kiln waste lances and one (1) kiln sludge lance feed the following types of materials: • Direct burn waste • Pumpable sludges • Pumpable liquids • No. 2 fuel oil The kiln waste lances are located in the kiln's frcintwall. The feed rate of each lance is controlled by a control valve located upstream of the lance and monitored by a flow meter. A -5 3M Section A 12/18//09 A.6.4 Kiln Sludge Lance The kiln sludge lance, like the kiln waste lances, penetrates the kiln's frontwall. Sludges are fed to the kiln sludge lance from the sludge processing room in Building 145 where highly viscous sludges are emptied into a sludge hopper that drains into the first of the two 2,150 gallon sludge storage tanks the batch tank. A pump mixes and recirculates the sludge and then transfers it to the second sludge storage tank or feed tank. A sludge pump moves waste from the sludge feed tank to the kiln sludge lance. Sludge is also fed to the sludge lance from the building 47 pump room. Currently, only one of these sludge systems (building 145 or building 47) can be operated at any given time, but future process modifications may allow the use of both systems simultaneously. A.6.5 Secondary Combustion Chamber Lance A single waste lance in the secondary combustion chamber feeds materials from the direct burn room. The feed rate to the lance is controlled by a control valve located upstream of the lance and monitored by a flow meter. A.7 COMBUSTION SYSTEM The combustion system consists of three major components: • Kiln frontwall • Rotary kiln • Secondary combustion chamber. A.7.1 Kiln Frontwall The kiln frontwall is a refractory- lined, steel casing firing hood that both seals off the kiln's feed end and provides the openings for the kiln burner, kiln waste lances, kiln sludge lance and kiln feed chute. Primary combustion air is injected into the kiln through a duct at the bottom of the front wall. A.7.2 Rotary Kiln The rotary kiln is a slowly rotating, refractory-lined steel cylinder where primary combustion occurs. The kiln is slightly tapered at both ends and slopes at 3.22 degrees toward the secondary combustion chamber. As the kiln rotates and the waste materials work their way to the discharge end of the kiln, vaporization and primary combustion of organics take place. A.7.3 Secondary Combustion Chamber (SCC) The flue gas exiting the kiln flows vertically upward through the secondary combustion chamber (SCC). The purpose of the SCC is to provide sufficient gas residence time, temperature, and turbulence to ensure complete combustion of residual organic materials. At the SCC outlet, a cross -over duct carries flue gas into the venturi quench. An emergency by -pass stack is located in the secondary chamber crossover duct. WIM. 3M Section A 12/18//09 A.8 ASH HANDLING SYSTEM The major components of the ash handling system include: • Ash quench conveyor • Ash collection and dewatering area Ash and residual solids separate from the flue gas stream in the lower portion of the secondary combustion chamber and drop into the water filled ash quench chamber which cools the residue and provides an air seal. A conveyor in the bottom of the chamber moves ash and residual solids upward from the quench to the ash collection and dewatering area, where they fall from the end of the conveyor into an ash - handling trailer. Ash and residual solids are then transferred to Containment building 181, where they are staged for shipment to an offsite TSDF. A.9 AIR POLLUTION CONTROL (APQ SYSTEM The major components of the air pollution control system include: • Quench • Subcooler • M1 module • Wet electrostatic precipitator (WESP) • Scrubber water collection and neutralization system • Induced draft (ID) fan • Stack. Detailed information on the air pollution control system is not included in this permit application. but are addressed in the Title V permit for the Facility. A.10 PROCESS MONITORING AND CONTROL The existing process control system includes the following components: • Field input and output devices • Distributed Process Control system (DCS) • Wet electrostatic precipitator (WESP) control system • Burner management system (BMS) • Incinerator waste tracking system (IWTS) • Continuous Emission Monitoring systems Detailed information on the process monitoring and control system is not included in this permit application. but are addressed in the Title V permit for the Facility. A -7 3M Section B 012/18/09 SECTION B WASTE DESCRIPTION This section describes the chemical and physical nature of the hazardous wastes handled, stored, and incinerated at 3MCottage Grove. Procedures for waste analysis are described in Section C of this permit application. The information in this section is in accordance with Minnesota Rules (M.R.) Part 7001.0560 B. 13.1 CHEMICAL AND PHYSICAL ANALYSIS has a comprehensive Waste Analysis Plan, as well as a Feedstream Analysis Plan required under MACT, which combine waste analyses performed at the generating locations with the waste analyses performed at the incinerator. These Plans assure that facility personnel have the waste composition knowledge needed in order to handle, store, incinerate, or ship each waste stream safely and properly. • The Plans provide sufficient analysis of waste at the appropriate frequency for the following purposes:Waste management decision making; • Waste transportation; • Waste handling and storage; • Verification upon receipt at the incinerator; • Feed control and documentation for incinerator permit feed restrictions; • Treatment or disposal off -site if applicable The basis for the waste analysis is the Waste Stream Profile completed by the generator of the waste. This analysis is adequate to meet all of the above purposes of the Plans. Backup for this Waste Profile may be either process knowledge, laboratory analysis, or an inventory or packing list of the contents in an individual container. 131.1 Waste Generating Locations The 3M Corporate Incinerator receives wastes from the following operations: (1) Wastes produced by facilities or processes that are owned, leased, or under the direct control of 3M. (2) Unused or off - specification 3M products returned by users to 3M. B -1 3M Section B 012/18/09 (3) Wastes produced by any facility (i.e., vendor shops and out - source manufacturing facilities) as a part of the manufacture of specific raw materials, chemical intermediates, or products used, purchased, or distributed by 3M. (4) Wastes accepted by 3M as a part of product exchange. (5) By- products or residuals from the processing of 3M raw materials, intermediates, products, and wastes. (6) Any other waste specifically approved by MPCA. (7) Wastes from non -3M sources 3M exercises great control over the 3M processes and facilities generating wastes received at Cottage Grove. 3M has intrinsic knowledge of products and wastes produced by 3M owned and leased facilities. In addition 3M has extensive knowledge of wastes that are produced by 3M vendor shops and out - source manufacturing. At these facilities, 3M may purchase raw materials and maintain ownership or in- process inventory and produced products. 3M may also write process standards and provide direct supervision of the manufacturing process. Off - specification products are transported to 3M in original 3M packaging and contain original 3M labeling and product identification numbers. For all wastes managed at the incinerator, including non -3M wastes, a waste stream profile must be completed before the waste is accepted at the 3M facility. The profile outlines the components and concentrations in the waste based on analytical data or knowledge of the waste providing the information needed to properly manage the waste. 13.1.2 Waste Categories The hazardous wastes stored and /or treated at this facility are listed in Table B -1 of this permit application. The wastes listed may be treated at the Cottage Grove facility, or stored for processing off -site. The hazardous wastes received each year are summarized in the facility's Annual Hazardous Waste Report, submitted to the Minnesota Pollution Control Agency each March. • The following waste categories are permitted for storage and treatment at the facility :Containers of liquids • Containers of sludges • Containers of solids • Bulk liquids • Bulk solids B -2 3M Section B 012/18/09 Containers of gases.Bulk waste from non -3M sources within the United Stated that have one of the following waste codes: • D001 • F001 • F002 • F003 • F005 Wastes generated by Minnesota Law Enforcement Agencies 13.1.3 Volume of Non -3M Wastes 3M is limited to processing 400,000 Million BTU's per year of wastes from non -3M sources. Minnesota Law Enforcement wastes that are processed are not included as a part of this volume. • 13.1.4 Waste Storage Catagories is stored on -site in containers and in bulk. Container storage, tank storage, and storage in a Containment Building are described in Sections S1 through S3 of this application. Segregation and /or blending of various wastes result in the following storage categories:Bulk Aqueous Wastes • Bulk Organic Solvent • Containers of solids, liquids, sludges, and gases • Bulk solids. • B.1.5 Incinerator Feed Categories from the above waste storage categories is either blended with other waste or fed directly to the incinerator in the following feed categories:Bulk Solvent • Pumpable Sludge • Direct Burn • Containers of Solids • Bulk Solids • Containers of Gases Materials in these categories are sampled and analyzed on a routine basis as described Section C. 13.1.6 Waste for Off -site Treatment or Disposal may be shipped off -site because the 3M Corporate Incinerator is not permitted to treat the waste, Land Disposal B -3 3M Section B 012/18/09 Restrictions (LDR) prevent treatment by incineration, the waste is a residue from treatment, or to maintain inventory at acceptable levels. B.2 CONTAINER STORAGE Containers are used to store the hazardous wastes listed in Table B -1. Containers used to store, hold, and transport hazardous waste received at the facility are in good condition. The containers are new, used, or reconditioned and are free or structural defects, leaks, or cracks that might impair their ability to hold the waste. Hazardous waste is stored only in containers that are constructed of materials compatible with the waste and that meet applicable codes and regulations. Selection of container materials of construction by the generator is based on knowledge of the processes from which the wastes are generated, knowledge of the materials of construction of those processes, physical and chemical analysis of the waste or prior experience of container use with waste materials. The specification for acceptable containers is also outlined in the Waste Stream Profile that is completed for each waste stream. Containers holding hazardous waste are managed to ensure safe operation as follows: • Each waste is analyzed or identified based on process knowledge in accordance with the Waste Analysis Plan. • Containers remain closed during storage and transportation except during sampling, filling, or removal of waste. • Handling of containers is conducted by trained operations personnel who have been instructed in hazardous materials handling. • Hazardous waste is not added to a container that previously contained or is holding material incompatible with the waste. • Containers are made from or lined with materials that have been shown acceptable for handling the specific hazardous waste. • All containers of hazardous wastes are labeled to facilitate proper handling and management practices. • Certain containers, due to the type of contents or potential hazards of the material, may be burned immediately upon receipt at the incinerator and are not stored on site. • Details regarding container management practices and container storage area design and operation are presented in Section S1. B.3 TANK STORAGE B -4 3M Section B 012/18/09 , The decant tank, waste solvent storage tanks, , and sludge tanks, as described in Section S2, are used to store hazardous wastes listed in Table B -1. All hazardous wastes handled or stored in tanks at the facility are analyzed in accordance with the Waste Analysis Plan /Feedstream Analysis Plan to account for compatibility with the materials of tank construction and compatibility with the contents of the tank prior to transfer of material to the storage tank. Prior to incineration, a representative sample from the tank is collected and analyzed. Concrete containment structures for each storage tank are sealed with a chemical resistant epoxy coating to protect and prevent penetration of spilled material into the concrete. Secondary containment for Tank 1 is constructed of steel plate. B.4 BULK SOLIDS STORAGE Management of bulk solids and ash residue storage is described in detail in Section S3 of this application. Analysis of these materials is in accordance with the waste analysis plan in Section C of this application. B.5 INCINERATOR WASTE FEED Waste analysis performed on all waste received and fed to the incinerator is in accordance with the Waste Analysis Plan /Feedstream Analysis Plan. B -5 3M Section B 012/18/09 Table - B1 List of Hazardous Waste Stored or Treated WASTE NUMBERS D001 F001 P017 P070' P127 UO28 U076 U123 U169 U219 U385 D002 F002 P018 P071 P128 UO29 U077 U124 U170 U220 U386 D003 F003 P020 P072 P185 UO30 U078 U125 U171 U221 U387 D004 F004 P021 P073 P188 UO31 U079 U126 U172 U222 U389 D005 F005 P022 P074 P189 UO32 U080 U127 U173 U223 U390 D006 F006 P023 P075 P190 UO33 U081 U128 U174 U225 U391 D007 F007 P024 P076 P191 UO34 U082 U129 U176 U226 U392 D008 F008 P026 P077 P192 UO35 U083 U130 U177 U227 U393 D009 F009 P027 P078 P194 UO36 U084 U131 U178 U228 U394 D010 F010 P028 P081 P196 UO37 U085 U132 U179 U234 U395 D011 F011 P029 P082 P197 UO38 U086 U133 U180 U235 U396 D012 F012 P030 P084 P198 UO39 U087 U134 U181 U236 U400 D013 F019 P031 P085 P199 U041 U088 U135 U182 U237 U401 D014 F020 P033 P087 P201 U042 U089 U136 U183 U238 U402 D015 F021 P034 P088 P202 U043 U090 U137 U184 U239 U403 D016 F022 P036 P089 P203 U044 U091 U138 U185 U240 U404 D017 F023 P037 P092 P204 U045 U092 U140 U186 U243 U407 D018 F024 P038 P093 P205 U046 U093 U141 U187 U244 U408 D019 F025 P039 P094 U047 U094 U142 U188 U246 U409 D020 F026 PO40 P095 0001 U048 U095 U143 U189 U247 U410 D021 F027 PO41 P096 0002 U049 U096 U144 U190 U248 U411. D022 F028 PO42 P097 0003 U050 U097 U145 U191 U249 D023 F039 PO43 P098 0004 U051 U098 U146 U192 U271 D024 PO44 P099 0005 U052 U099 U147 U193 U277 D025 MNO PO45 P101 0006 U053 U101 U148 U194 U278 1 D026 MNO PO46 P102 0007 U055 U102 U149 U196 U279 2 D027 MNO PO47 P103 0008 U056 U103 U150 U197 U280 3 D028 MNO PO48 P104 0009 U057 U105 U151 U200 U328 4 D029 PO49 P105 U010 U058 U106 U152 U201 U353 D030 P001 P050 P106 U011 U059 U107 U153 U202 U359 D031 P002 P051 P108 U012 U060 U108 U154 U203 U364 D032 P003 P054 P109 U014 U061 U109 U155 U204 U365 D033 P004 P056 P110 U015 U062 U110 U156 U205 U366 D034 P005 P057 P111 U016 U063 U111 U157 U206 U367 D035 P006 P058 P112 U017 U064 U112 U158 U207 U372 D036 P007 P059 P113 U018 U066 U113 U159 U208 U373 D037 P008 P060 P114 U019 U067 U114 U160 U209 U375 D038 P009 P062 P115 UO20 U068 U115 U161 U210 U376 D039 P010 P063 P116 UO21 U069 U116 U162 U211 U377 D040 P011 P064 P118 UO22 U070 U117 U163 U213 U378 D041 P012 P065 P119 UO23 U071 U118 U164 U214 U379 D042 P013 P066 P120 UO24 U072 U119 U165 U215 U381 D043 P014 P067 P121 UO25 U073 U120 U166 U216 U382 P015 P068 P122 UO26 U074 U121 U167 U217 U383 P016 IP069 I P123 I UO27 I U075 I U122 I U168 I U218 IU384 SECTION C WASTE ANALYSIS PLAN 3M Corporate Incinerator Waste and Fbeeo%dstream Analysis Plans (WAP/FAP) Data Requirements 40CFR63.1209(c) (2) 40CFR63.8 (f) Minn. R. 7045.0458; 7045.0456; 70460542; 7045.1390; and 7001.0560 Air Emission Permit No. 16300025 -001 January 25, 2012 Page C -1 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator TABLE OF CONTENTS Tableof Contents ......................................................................................................... ..............................2 Listof Tables ................................................................................................................. ..............................4 1 Waste Analysis Plan Summary .......................................................................... ............................... 5 2 Feedstream Description ....................................................................................... ..............................5 2.1 Bulk Liquids ................................................................................................... ............................... 6 2.2 Non -bulk Material .......................................................................................... ............................... 6 2.3 Auxiliary Fuel ................................................................................................ ............................... 6 3 Waste Stream Pre - Acceptance Procedures ....................................................... ..............................6 3.1 Waste Stream Profile Submission .................................................................. ............................... 6 3.2 Waste Stream Profile Review ........................................................................ ............................... 6 3.3 Waste Stream Profile Approval ..................................................................... ............................... 7 4 Incoming Waste Inspection Procedures ............................................................. ..............................7 4.1 Receiving Procedures ..................................................................................... ............................... 7 4.2 Fingerprint Analyses ...................................................................................... ............................... 8 4.3 Finger Print Analysis Exceptions ................................................................... ............................... 8 5 Laboratory Analysis Performed Prior to Incineration .......................................... ..............................9 5.1 Blended Bulk Solvent .................................................................................... ............................... 9 5.2 Non -bulk Pumpable Material, Blended .......................................................... ............................... 9 5.3 Non -bulk Material .......................................................................................... ............................... 9 5.4 Auxiliary Fuel .............................................................................................. ............................... 10 6 Waste Stream Profile Verification ....................................................................... .............................10 6.1 Annual Waste Stream Profile Verification ................................................... ............................... 10 6.2 Waste Stream Profile Verification for 3M Generated Wastes ..................... ............................... 10 6.3 Waste Stream Profile Verification for 3M Generated Wastes from Vendor Shops .................... 11 6.4 Waste Stream Profile Verification for Wastes from 3M Distribution Centers ............................ 11 6.5 Waste Stream Profile Verification for Wastes from Other Generators ........ ............................... 11 6.6 Independent Analysis Verification ............................................................... ............................... 12 6.7 Additional Sampling Events ........................................................................ ............................... 12 6.8 Wastes Exempted from Sampling Requirements ......................................... ............................... 12 7 Methods for Documenting Compliance .............................................................. .............................14 8 Analysis Parameters and Rationale ................................................................... .............................14 9 Waste Analysis Test Methods ............................................................................ .............................15 10 Waste Sampling Methods ................................................................................... .............................16 11 Off -site Waste Analysis ....................................................................................... .............................17 12 Incinerator Waste Tracking System ........... 13 Additional Waste Analysis Requirements.. ................................................... .............................17 ................................................... .............................17 Page C -2 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator 14 Quality Control ..................................................................................................... .............................18 15 Recordkeeping .................................................................................................... .............................18 16 References .......................................................................................................... .............................18 17 Revision History .................................................................................................. .............................18 Page C -3 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator LIST OF TABLES Table 1: Waste Analysis Selection Rationale ............................15 Table 2: Waste Analysis Test Methods ........ .............................16 Table 3: Waste Sampling Methods ............... .............................16 Table 4: Waste Review, Fingerprinting, and Analysis Matrix ... 20 Page C -4 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator 1 Waste and Feedstream Analysis Plan Summary The Waste and Feedstream Analysis Plan (WAP /FAP) for the 3M Cottage Grove Corporate Incinerator describes the procedures which 3M will use to comply with the RCRA waste analysis requirements found in Minn. R. 7045.0458, 7045.0456; 7045.0542; 7045.1390, and 7001.0560, and the requirements found in 40CFR63.1209(c)(2) and the general provisions in 40CFR63.8(f). This Plan satisfies the requirements of both required documents. This Plan will establish necessary sampling methodologies, analytical techniques, and overall procedures for characterization, acceptance, storage, treatment and /or disposal of hazardous wastes accepted or generated at the facility. This Plan provides sufficient analysis of waste at the appropriate frequency for the following purposes: Waste management Waste transportation Waste handling and storage Verification upon receipt at the 3M Incinerator Feed control and documentation for Incinerator permit feed restrictions Treatment or disposal off -site if applicable The 3M Corporate Incinerator was built in 1971. Located at 10746 Innovation Road, Cottage Grove, Minnesota, the Facility is owned and operated by 3M. The 3M Corporate Incinerator provides treatment and storage for both hazardous and non - hazardous business - related wastes generated by 3M's business operations throughout North America. The Facility also treats wastes not generated by 3M. The types of containerized wastes received at the Facility include solids, gases in cylinders, pumpable sludges, organic liquids, and aqueous liquids. Waste storage facilities include indoor and outdoor container storage areas, outdoor bulk liquid tanks, a containment building for bulk solids storage, and outdoor trailer storage areas. The incinerator itself is a rotary kiln with a secondary combustion chamber. No land disposal of hazardous waste is conducted at the Facility. The Facility consolidates shipments of some 3M wastes for disposal at outside hazardous waste facilities. Analysis for treatment or disposal off -site is dependent upon the requirements of the off -site facility. The 3M Company has a unique and comprehensive knowledge of 3M generated waste streams. This knowledge is based on its years of operating experience, a close partnership with 3M manufacturing facilities, and specific corporate training and waste identification programs. This knowledge is an integral part of this Plan. For non 3M wastes, where we do not have the same level of knowledge of the waste, additional sampling and analyses will be required along with information provided by the generator when obtaining a Waste Stream Profile. 2 Feedstream Description The incineration system is designed to handle a variety of wastes introduced through four separate feed systems, depending on the waste stream. Solids are fed through a bulk feed chute (pakfeeder and Komar shredder); pumpable liquids are fed through lances or the frontwall burner; and sludge is fed through a lance from the Building 145 sludge room. Materials received at the Facility fall into one of three basic categories: bulk liquids, non -bulk material, and auxiliary fuel. Page C -5 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator 2.1 Bulk Liquids Bulk liquids arrive at the Facility in tanker trucks and are normally pumped into one of several storage tanks. Waste from these tanks may be introduced into the incinerator through a waste lance in the front wall of the rotary kiln or the secondary combustion chamber, or through a burner in the rotary kiln. 2.2 Non -bulk Material Non -bulk materials are shipped to the Facility in several types of containers, including steel drums, totes, plastic and fiber drums, pails, boxes, bags, gas cylinders and portable tanks. Containerized liquids are typically fed into the kiln through a lance from the Building 145 sludge room. They may also be transferred directly to a waste lance through the direct burn line originating in Building 145. Containerized solids may be fed into the kiln via the Komar shredder or the drum feeder through the feed chute. Containerized gasses are fed into the secondary combustion chamber through a waste lance. 2.3 Auxiliary Fuel The Facility uses natural gas and #2 fuel oil as supplemental fuels. Either may be fed into the system through the burners in the kiln. Fuel oil may also be introduced through any of the waste lances. 3 Waste Stream Pre - Ac ceptance Procedures Each waste stream profile submitted for shipment to this Facility is evaluated in the following manner. Any analysis performed for waste stream profile submission will use approved test methods (EPA, ASTM, etc.). 3.1 Waste Stream Profile Submission Each generator seeking to ship waste to this Facility must first submit a waste stream profile request. This request must include information sufficient to comply with Minn. R. 7045.0214. For wastes not generated by 3M, the profile request must include analysis of the waste (except for law enforcement wastes, as described in Section 4.3). For 3M- generated waste, the request may be accompanied by analytical data, or make use of process knowledge and supplemented by the Corporate Chemical Data Management System (CDMS). The Corporate Chemical Data Management System (CDMS) contains information on the raw materials, intermediates, and products manufactured by 3M. The system is maintained under the direction of Corporate Material EHS /Medical. It has been designed to assist with compliance with regulations such as TSCA, RCRA, EPCRA, WEEE/RoHS, the OSHA Hazard Communication Standard, and with the generation of MSDS information. Through this system, products can be traced back to the raw materials used in their manufacture. 3.2 Waste Stream Profile Review Prior to waste stream profile approval, the request is reviewed by the Waste Stream Profile Administrator for completeness, for proper packaging and shipping instructions, and to gather any additional information required before the waste is accepted. This process may involve requesting that an analysis be performed by the generator, or further description of the waste characteristics. The Waste Stream Profile program software (WSP) automatically flags RCRA waste codes that require additional evaluation under Minn. R. 7045.1390. These wastes receive a Do Not Incinerate (DNI) code in the WSP system to ensure they are not incinerated without this review. Page C -6 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator 3.3 Waste Stream Profile Approval Before a new waste is accepted, each waste stream profile request is reviewed, at a minimum, by the following Facility representatives: EHS, Facility Operations, and a Waste Stream Profile administrator. The process is described in SOP -1015, "Waste Review Meeting." Absence of representation from any job function will result in meeting cancellation. Waste streams will not be approved unless the representatives of each job function are satisfied that sufficient information is available to comply with Minn. R. 7045.0214, 7045.0450 to .0551, 40 CFR 63 subpart EEE, OSHA standards, DOT regulations, and operational needs. Waste streams may be conditionally approved, and the waste sampled and analyzed by the on -site laboratory prior to incineration to ensure conformance to the Waste Stream Profile. Waste streams may also be approved for shipment to the Facility for consolidation, storage, and shipment to another disposal facility. Examples of these types of waste include program waste (circuit boards, broken fluorescent bulbs, etc.), or any other waste the Facility cannot process due to its permit or operational constraints. Wastes of this type are assigned a Do Not Incinerate (DNI) code that prevents it from being processed at this Facility. 4 Incoming Waste Inspection Procedures Waste received at the Facility is inspected for conformance to the waste stream profile in the following manner. Each shipment of waste is inspected, sampled and analyzed as defined herein before acceptance, except as noted in Section 4.3. This serves two purposes. First, it compares the actual waste identity with that determined in the pre- acceptance phase and the waste manifest. Second, it further ensures proper disposition of the waste for treatment, storage, and /or disposal. Waste shipments, which have arrived on -site, are considered to be in the receiving process until a final decision regarding waste acceptability is made; at such time the wastes are considered accepted or are rejected. 4.1 Receiving Procedures Upon arrival of a waste shipment at the 3M Corporate Incinerator, the accompanying manifest is reviewed by 3M personnel for completeness and the shipment is inspected for agreement with the manifest information. The following procedures describe this inspection process: • SOP -2001, "Receiving Shipments of Containerized Waste", container inspection procedures, container tracking and storage procedures, manifest reconciliation procedures, manifest copy distribution procedures. • SOP -2002, "Receiving Tankers ", tanker inspection procedures, tanker material tracking procedures, manifest procedures. • SOP -2004, "Incoming Manifest Processing ", procedures for arranging transportation of materials from on -site to the incinerator facility, container inspection and discrepancy resolution procedures, container tracking and storage procedures. • SOP -2052, "Waste from Non -3M Locations ", procedures for approving shipments from non - 3M locations, waste stream profile requirement, label and manifest procedures, annual notification and certification requirements. Non -3M generated bulk wastes will arrive with a detailed chemical analysis as described in Section 6.5. Incoming shipments are sampled and analyzed for the Fingerprint Parameters as identified in Section 4.2 and any supplemental analyses specified during the Waste Stream Profile approval process. Subject to the exceptions in Section 4.3, 3M generated bulk waste loads are sampled and analyzed for fingerprint parameters. In the case of shipments of non -bulk 3M Vendor wastes including trans - shipments, 10% of each WSP Page C -7 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator will have a fingerprint analysis performed, except as provided in Section 4.3. All other non -bulk 3M generated waste will have, at a minimum, external visual inspections for container integrity, labeling, and weight. All fingerprint analyses will be completed within 48 hrs of the unloading of the waste shipment except in the cases where the waste processing has an irregular schedule. This would include direct burn liquids, direct burn liquids to the SCC tower, adhesive cylinders, and Komar special runs. The fingerprint analyses would be conducted just prior to the time of processing on the required number of drums. 4.2 Fingerprint Analyses Fingerprint Analyses consist of basic screening procedures performed to provide general waste identification. Table 4 provides a summary table of the types of fingerprint analyses performed on each type of waste. The fingerprint analysis is compared with the waste characteristics provided in the WSP, manifest, and /or shipping papers. These analyses may be used in conjunction with other waste analyses and information to further identify a waste and /or ensure the type of on -site management chosen is suitable for that particular waste. At a minimum, all remaining containers which do not receive a fingerprint analysis are visually inspected for container integrity, labeling, and are weighed prior to processing. If a non - conformance in the fingerprint analysis is discovered, the contents of all of the containers for that waste stream in that particular shipment are inspected. The parameters and associated rationale of the fingerprint analyses are as follows: • Physical Description (appearance /color) is used to determine the general properties of the waste. This facilitates comparison of the sampled waste with prior waste descriptions or samples. It is also used to verify the presence or absence of free standing liquid, as well as any obvious change in physical properties. The physical description is initially broken into three categories: solid, liquid, or multi - phase. Each category will have a descriptive list of choices that will further describe the physical appearance. Solid descriptions will include but not limited to: granular, powder, rags, bags, gloves, paper, and construction debris. Liquid descriptions will include but not limited to: pumpable (thin liquid), pourable (thick liquid), clear, and milky. • Chemical Reactivity Screen (Chemical Compatibility) is used to determine whether the waste has a potential to vigorously react with other chemicals when mixed together to form gases or other products, or whether it generates significant heat. SOP -3051, "Tank Farm Bulk Compatibility Testing" (compatibility testing procedures for all tanker -to -tank and tank -to -tank waste transfers) and SOP -3052, "Sludge Hopper Compatibility Testing" (compatibility testing procedures for sludge processing) describe the methodology for testing incoming and stored waste. This test will only be conducted on wastes that will be mixed with other wastes in the sludge and solvent systems. Any chemical reactions that exhibit the following characteristics: foaming, bubbling, polymerization, the evolution of gas, or a rise in temperature, will result in a non - conformance. • pH Screen is undertaken to indicate the corrosive nature of the waste. pH may not apply to certain waste types, (e.g., organic wastes, oil waste, or wastes which are not water soluble). Ph ranges will include less than or equal to 2, three ranges between 2 and 12.5, and greater than or equal to 12.5. These ranges will be defined in standard operating documents and will be determined by reviewing DOT classifications, best package engineering practices, and appropriate storage container materials of construction. • Weight of the waste container can be used in some instances to determine the general properties of the waste specifically for empty/near empty containers or containers where the primary contents are lightweight materials like rags, bags, and PPE. 4.3 Finger Print Analysis Exceptions Exceptions to the foregoing requirements include the following: • Waste contained in a Lab -Pack or combination packaging. Combination packaging is defined in 49 CFR §171.8 as "...one or more inner packagings secured in a non -bulk outer packaging." This will also include single containers less than 23 liters. The generator will provide a Page C -8 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator detailed shipping list of chemicals in the Lab Pack which will be used for determining RCRA and MACT feed rate compliance. • Unopened commercial products or chemicals. This also includes products voluntarily removed from the market place by a manufacturer or distributor. • Controlled substances regulated by government agencies including drugs and /or materials. • Pressurized or liquefied gases. The containers will be weighed prior to processing but no additional finger print analysis will be performed. • Residue and debris from the cleanup of spills or releases of a waste which would otherwise qualify as an exception. This does not include spills that contain a mixture of exempted waste and environmental media such as soils and sump sludges except where listed below. • In addition, 3M may waive incoming finger print analysis where the preacceptance documentation supplies sufficient information to assure compliance with permit conditions and operational constraints, and any of the following conditions exist: • Obtaining a finger print analysis poses a substantial and unnecessary exposure hazard to facility employees. This includes sharps, isocyanates, strong oxidizers, and similar compounds. • The material may react violently with air or moisture. Examples include: isocyanates, hydrogen fluoride. • The material's odor poses a public nuisance when inspected; or • Biological wastes, including infectious substances, tissue samples, etc. 5 Laboratory Analysis Performed Prior to Incineration For processing purposes, materials processed at the Facility are divided into the following categories: bulk solvent, non -bulk pumpable material, non -bulk material, and auxiliary fuel. 5.1 Blended Bulk Solvent Bulk storage tanks contain blended liquid waste from individual tanker trucks. When a storage tank has been filled a sample is taken of the blended waste. Analysis must be performed prior to incineration to determine the heating value (BTU), percent ash, percent chlorine, and metals content of the blended waste. Metals analysis includes arsenic, cadmium, chromium, cobalt, nickel, and lead. Non - detected values will be entered as half the detection limit for each specific element and test. Data for sulfur, ash, beryllium and mercury will be taken from the waste stream profiles of the individual components of the blended waste. This process is performed by the IWTS software and is described in section 12. 5.2 Non -bulk Pumpable Material, Blended Non -bulk pumpable material is blended in a batch tank for introduction into the kiln. Analysis must be performed prior to incineration to determine the heating value (BTU), percent ash, and metals content of the blended waste. Metals analysis includes arsenic, cadmium, chromium, cobalt, nickel, and lead. Non - detected values will be entered as half the detection limit for each specific element and test. Data for sulfur, ash, beryllium, and mercury will be taken from the waste stream profiles of the individual components of the blended waste. This process is performed by the IWTS software and is described in section 6. 5.3 Non -bulk Material A qualitative inspection of non -bulk non - pumpable material is conducted as described in Section 4 above. Page C -9 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator Data for BTU, chlorine, sulfur, ash, arsenic, beryllium, chromium, cadmium, lead and mercury will be taken from the waste stream profile. 5.4 Auxiliary Fuel A sample of the #2 fuel oil received at the Facility had been sent to a certified laboratory approximately monthly for a period of more than 2 years. This data was used to generate an average profile of the fuel oil for the following constituents: BTU, chlorine, sulfur, ash, % water, arsenic, beryllium, cadmium, chromium, lead and mercury. A sample of the #2 fuel oil received at the Facility will be sent to a certified laboratory at least annually to verify the continued accuracy of the historical data for the constituents listed above. Natural gas constituent concentrations will be supplied by the vendor or another published source. 5.5 Sand for Flux A sample of the sand received at the Facility will be sent to a certified laboratory at least annually for the following constituents: arsenic, beryllium, cadmium, chromium, lead and mercury. 6 Waste Stream Profile Verification The Building 145 Laboratory, or an independent certified laboratory, will carry out analytical verification of the Waste Stream Profiles as described below. 6.1 Annual Waste Stream Profile Verification Each active waste stream profile goes through a mandatory review on an annual basis. The waste generator certifies that the waste is accurately described by the waste stream profile, that the generation process has not changed, and that the physical and chemical properties of the waste are correct. If the waste stream has not changed, the waste will be certified for receipt for another year. If the waste stream has changed, the waste stream profile will be updated, or a new profile generated. The waste stream profile must then be resubmitted for approval as described in Section 3. Additionally, any analysis previously performed on the waste would be considered invalid, and the waste subjected to verification as described below. 6.2 Waste Stream Profile Verification for 3M Generated Wastes Individual waste stream profiles comprising the top 90% of waste received at the Incinerator (in terms of mass) will be analyzed and verified by the Laboratory at least once every five years, unless excepted as described in Section 6.8. Analysis will be conducted on at least seven samples per waste stream for the following: ash, heating value, chlorine, arsenic, beryllium, chromium, cadmium, cobalt, nickel, lead and mercury. Other analytes may be added as desired. Data generated for a given waste stream will be examined for anomalous readings due to laboratory or other errors. Examples include bad laboratory analysis (QA/QC problems, transcription errors), a known process upset causing a change in the nature of the waste, or another documented reason. Data points will not be eliminated unless they meet the standards described above. A concentration range (95% confidence interval) will be calculated for each analyte, and that interval will be used to update the WSP, if needed. The reporting limit for RCRA metals will be sufficiently low to ensure metals values below the reporting limit will not adversely impact compliance with feedrate limits, not to exceed 25 mg /kg for As, Be, Cd, Cr, Co, Ni, and Pb. For results below the reporting limit, a value of one half the reporting limit will be substituted for zero in the calculation of a range for that analyte. The 95% confidence interval will then be calculated. If the maximum value and the highest individual data point are below the reporting limit for that analyte, the Page C -10 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator constituent will not be included in the waste stream profile. If either the maximum value or the highest individual data point (or both) is above the reporting limit, the constituent will be included in the waste stream profile. Mercury reporting limits will be targeted at or below 10 ug /kg for Hg in liquids, and 50 ug /kg for Hg in solids (if the reporting limits are above these levels, any undetected values will be reported as the method reporting limit). For analyses that meet the targeted reporting limits, and mercury is detected between the reporting limit and detection limit ( "J" flags), the reported concentration will be used to add a Hg value to the waste stream profile. If all samples analyzed for Hg are below the detection limit, half the reporting limit will be added to the waste stream. Discretionary verification of low quantity (in terms of mass) waste streams (not in the top 90% volume) may be performed at any time. A minimum of 15% of the annual volume of the waste (in terms of drum equivalents) will be sampled, up to 7 samples. The data generated will be treated in the same manner as described above. 3M will test a minimum of 100 of these low mass waste streams per year. Emphasis will be placed on wastes that are further removed from the manufacturing process, such as general plant clean -up or process area.clean -up. 6.3 Waste Stream Profile Verification for 3M Generated Wastes from Vendor Shops Waste from vendor shops contracted by 3M will be subject to the provisions described in Section 6.2. In addition, vendor shop waste will require sampling to determine conformance with the Waste Stream Profile when the waste stream is received for the first time. Analysis will be conducted for the following: ash, heating value, chlorine, arsenic, beryllium, chromium, cadmium, cobalt, nickel, lead and mercury. Other analytes may be added as desired. The reporting limit for RCRA metals will be sufficiently low to ensure metals values below the reporting limit will not adversely impact compliance with feedrate limits, not to exceed 25 mg /kg for As, Be, Cd, Cr, Co, Ni, and Pb. For results below the reporting limit, a value of one half the reporting limit will be substituted for zero in the calculation of a range for that analyte. The 95% confidence interval will then be calculated. If the maximum value and the highest individual data point are below the reporting limit for that analyte, the constituent will not be included in the waste stream profile. If either the maximum value or the highest individual data point (or both) is above the reporting limit, the constituent will be included in the waste stream profile. Mercury reporting limits will be targeted at or below 10 ug /kg for Hg in liquids, and 50 ug /kg for Hg in solids (if the reporting limits are above these levels, any undetected values will be reported as the method reporting limit). For analyses that meet the targeted reporting limits, and mercury is detected between the reporting limit and detection limit ( "J" flags), the reported concentration will be used to add a Hg value to the waste stream profile. If all samples analyzed for Hg are below the detection limit, half the reporting limit will be added to the waste stream. 6.4 Waste Stream Profile Verification for Wastes from 3M Distribution Centers Waste from 3M Distribution Centers consists primarily of finished products. As such, each container sent to the Facility for disposal is unique. These wastes arrive at the Facility with a packing slip detailing the contents of each container. The products, and the mass of each product, are entered into the CDMS system to determine what constituents are present in the container of waste. Waste streams of this type receive a Do Not Incinerate (DNI) code to ensure they are not incinerated before this analysis is performed and the results entered into the IWTS system for tracking. 6.5 Waste Stream Profile Verification for Wastes from Other Generators All non -3M waste received at the Facility must have an approved 3M- generated Waste Stream Profile. The profile request must be accompanied by an analysis of the waste for PCBs, heating value, chlorine, arsenic, beryllium, chromium, cadmium, cobalt, nickel, lead and mercury. 3M will review the Page C -11 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator quality control data along with the report to determine its acceptability. Law enforcement wastes will be accompanied by a detailed packing slip in lieu of this analysis. Waste that does not conform to the waste stream profile and /or the acceptance specifications set forth by 3M will be rejected and returned to the Generator. After a statistically significant number of samples have been tested by the generator and these verify that the general composition and characteristics of the waste stream match the Waste Stream Profile, the generator will be required to supply comprehensive analytical data for PCBs, heating value, chlorine, arsenic, beryllium, chromium, cadmium, cobalt, nickel, lead and mercury four times per year, or when the generator has reason to believe the process or operation generating the waste has changed in a manner which may change the characteristics of the waste. In addition to the testing performed by the waste generator, the Facility's Laboratory will verify the ash, heating value, chlorine, arsenic, beryllium, chromium, cadmium, cobalt, nickel, lead and mercury content of the waste at the same or greater frequency as for 3M generated wastes. The reporting limit for RCRA metals will be sufficiently low to ensure metals values below the reporting limit will not adversely impact compliance with feedrate limits, not to exceed 25 mg /kg forAs, Be, Cd, Cr, Co, Ni, and Pb. For results below the reporting limit, a value of one half the reporting limit will be substituted for zero in the calculation of a range for that analyte. The 95% confidence interval will then be calculated. If the maximum value and the highest individual data point are below the reporting limit for that analyte, the constituent will not be included in the waste stream profile. If either the maximum value or the highest individual data point (or both) is above the reporting limit, the constituent will be included in the waste stream profile. Mercury reporting limits will be targeted at or below 10 ug /kg for Hg in liquids, and 50 ug/kg for Hg in solids (if the reporting limits are above these levels, any undetected values will be reported as the method reporting limit). For analyses that meet the targeted reporting limits, and mercury is detected between the reporting limit and detection limit ( "J" flags), the reported concentration will be used to add a Hg value to the waste stream profile. If all samples analyzed for Hg are below the detection limit, half the reporting limit will be added to the waste stream. 6.6 Independent Analysis Verification The Building 145 Laboratory is not a state certified laboratory, so it will conduct parallel analysis with a certified laboratory for verification purposes. One sample of an individual waste stream or blended waste, as determined by the Laboratory Group Leader, will be sent to a certified laboratory each week (these samples may be collected over several weeks and shipped less frequently if desired). Concurrent analysis will be performed in the Building 145 Laboratory, and results compared for the following analytes: ash, heating value, chlorine, arsenic, beryllium, chromium, cadmium, cobalt, nickel, and lead. Other analytes may be added as desired. Results of these tests will be maintained by the Laboratory and made available upon request. 6.7 Additional Sampling Events The Building 145 Laboratory may conduct additional sampling as desired. Circumstances that may prompt additional sampling include process changes initiated by a waste generating facility, suspicion of WSP inaccuracies, or a request by Facility personnel. Additionally, new waste streams may require compatibility screening before they are blended with other wastes. 6.8 Wastes Exempted from Sampling Requirements Exceptions to the foregoing requirements include the following: • Waste contained in a Lab -Pack or combination packaging. Combination packaging is defined in 49 CFR §171.8 as "...one or more inner packagings secured in a non -bulk outer packaging." The generator will provide a detailed shipping list of chemicals in the Lab Pack which will be used for determining RCRA and MACT feed rate compliance. Page C -12 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator • Unopened commercial products or chemicals. This also includes products voluntarily removed from the market place by a manufacturer or distributor. • "Empty" containers of waste materials, commercial products or chemicals. This applies to portable containers which have been emptied, but which may hold residues of the product, chemical, or containers containing other empty containers. Examples of containers are: tanks not exceeding 4'x4', totes, drums, barrels, cans, bags, liners, etc. A container shall be determined "empty" according to the criteria specified at Minn. R. 7045.0127 Subp. 2. Specifically, a container can be considered empty if it did not contain a waste that is a compressed gas or that is identified as an acute hazardous waste in part 7045.0135, Subpart 1 a, items B and C, and Code of Federal Regulations, title 40, section 261.33(e), as incorporated in part 7045.0135, and: • all wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container such as pouring, pumping, and aspirating; and • no more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner; or o no more than three percent by weight of the total capacity of the container remains in the container or inner liner if the container or inner liner is less than or equal to 119 gallons in size; or o no more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container or inner liner is greater than 119 gallons in size. For containers that held acute waste, a container can be considered empty if: • the container or inner liner has been triple rinsed using a solvent capable of removing the commercial chemical product or manufacturing chemical intermediate; • the container or inner liner has been cleaned by another method that has been shown in the scientific literature, or by tests conducted by the generator, to achieve equivalent removal; or • in the case of a container, the inner liner that prevented contact of the commercial chemical product or manufacturing chemical intermediate with the container, has been removed. For containers that held compressed gases, a container can be considered empty when the pressure approaches atmospheric pressure. • Wastes which are visually identifiable through an inspection process. Examples may include filters and filter cartridges, wire or tubing, paper products, metal sheeting and parts, crushed glass, piping, and other debris. • 3M Incinerator generated waste, including hazardous and non - hazardous waste. • Controlled substances regulated by government agencies including drugs and /or materials. • Residue and debris from the cleanup of spills or releases of a waste which would otherwise qualify as an exception in Section 6.8. This does not include spills that contain a mixture of exempted waste and environmental media such as soils and sump sludges except where listed below. • Materials designated for storage and trans - shipment off -site. These materials are received for storage and subsequent trans - shipment only and are not otherwise actively managed on -site. If it is determined 3M will process a waste previously designated for storage and subsequent trans - shipment, the waste will be reviewed utilizing the normal approval process prior to on -site processing. Page C -13 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator • Aerosol cans. • Pressurized or liquefied gases. The containers will be weighed prior to processing but no additional analysis will be performed. • Vitrified, cemented, and other materials exhibiting high structural integrity. Certain materials are not conducive to sampling. Structural steel, tanks, pipe, cement, glass, empty drums, machinery, equipment, manufactured items, monolithic/ cemented materials, and several other materials are managed which do not allow for normal sampling protocols. By necessity, these materials must be managed on a case -by -case basis. • In addition, 3M may waive incoming waste load sampling and analysis where the preacceptance documentation supplies sufficient information to assure compliance with permit conditions and operational constraints, and any of the following conditions exist: o Obtaining a representative sample poses a substantial and unnecessary exposure hazard to facility employees This includes sharps, isocyanates, strong oxidizers, and similar compounds; o The material may react violently with air or moisture (examples include isocyanates, and hydrogen fluoride); • The material's odor poses a public nuisance when sampled; or • Biological wastes, including infectious substances, tissue samples, etc. 7 Methods for Documenting Compliance Pursuant to 40 CFR 63.12091(2)(iii), compliance with applicable feedrate limits will be demonstrated by taking the concentration of each constituent in each feedstream, monitoring the flow rate and summing over all the feedstreams. These calculations are performed by the IWTS software, which contains all of the constituent concentrations in each waste stream profile, and tracks the movements and disposal of each waste stream. For blended wastes, the concentration of each constituent not directly tested prior to incineration (sulfur, beryllium, mercury, ash) will be calculated as follows: the concentration for each constituent listed in the WSP of each waste in the batch (in lb/lb) will be multiplied by the weight of the waste and summed for all the wastes in the batch, then divided by the total weight of the batch. The result will be a lb/lb concentration of each constituent in the batch. For blended wastes, non - detectable quantities of individual analytes will be entered as one half the reporting limit for constituents that were tested prior to incineration (except mercury, which will be entered as the reporting limit), or as zero for constituents taken from individual waste stream profiles. 8 Analysis Parameters and Rationale Before an owner or operator treats, stores, disposes any material, Minn. R. 7045.0458, Subp. 2.A requires a facility to obtain sufficient information on the waste's properties to comply with Minn. R. 7045.0458, Subp. 1.A The 3M Company has a unique and comprehensive knowledge of 3M generated waste streams. This knowledge is based on its years of operating experience, a close partnership with 3M manufacturing facilities, and specific corporate training and waste identification programs. This knowledge is an integral part of the Corporate Incinerator's WAR For non 3M wastes, where we do not have the same level of knowledge of the waste, additional sampling and analyses will be required along with information provided by the generator when obtaining a Waste Stream Profile. The 3M Corporate Waste Management Program provides tools and guidance necessary to implement an effective and environmentally sound solid and hazardous waste management program that Page C -14 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator includes: compliance with waste regulations, 3M policies and standards, proper management of containerized solid and hazardous waste, pollution prevention and waste minimization, accurate identification, preparation, and shipment of waste, site coordinators, and annual training programs. The 3M Waste Stream Profile (WSP) Program provides detailed chemical and physical characteristics of the waste streams managed at the incinerator. This program also utilizes 3M corporate databases for MSDS and chemical composition information. The Waste Receiving Procedure verifies that the delivered waste matches the accompanying manifest, has the required waste stream profile documentation, and meets the conditions of the incinerator's permit. The Incinerator Waste Tracking System (IWTS) documents the authorization for storage and treatment and tracks the movement and disposal of waste containers within the Facility. In addition to 3M's process knowledge and the information provided by the WSP system, the parameters for which materials may be analyzed and the rational for selection are: Table 1: Waste Analysis Selection Rationale Parameter Rationale for Selection Ash Content Identifies wastes with high particulate content that may compromise air emission compliance and incinerator performance. Chlorine Content Determine conformance with operational acceptance limits for chlorine content to ensure compliance with HCI controls under 40 CFR 264/265.343. Heating Value To be able to produce a consistent quality of fuel. This information allows personnel to selectively mix (BTU) shipments so the final fuels have a heating value that is consistent for reliable combustion. Metals Determine conformance with Feedstream requirements in 40 CFR 63 Subpart EEE. Organic Composition Suspected waste streams containing unacceptable levels of extremely hazardous chemicals or compounds. Percent Moisture Identifies waste with extensive moisture content. pH Identifies wastes that may corrode incinerator system components. Visual /Physical Used to determine the general characteristics of the waste stream. This facilitates subjective comparison of sample with profile. Compatibility/ Reactivity Used to determine if the material is blendable and non - reactive. 40 CFR 261, Appendix III Identi fY prohibited hazardous waste constituents that Principal Organic Hazardous Constituents (POHCs) Constituents selected for trial burn may not have addressed. 9 Waste Analysis Test Methods Minn. R. 7045.0458, Subp. 2.13. requires a facility to address the test methods that will be used for the parameters outlined in Section 2 of this Plan. The analytical methods used to generate waste stream data will be based on the following standard methods: Page C -15 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator Table 2: Waste Analysis Test Methods Parameter SW846 Test Method EPA Test Method ASTM Test Method BTU - - D240 Percent Ash - - D482 Percent Chlorine 5050 - D4208 pH 9041A 9040C or 9041A D4980 Metals 3010A, 3031, 3050B, 6010, 6200, 7470, 7471 200.7 - Total Fluoride 1 5050 1 D3761 All other laboratory methods must be those specified in the latest addition of: U.S. EPA publication Test Method for Evaluating Solid Waste: Physical /Chemical Methods SW -846; Standard Methods for the Examination of Water and Wastewater; Methods for the Determination of Metals in Environmental Samples: EPA - 600/4 -91 -010; Methods for the Chemical Analysis of Water and Wastes: EPA- 600/4 -79- 020; American Society for Testing and Materials (ASTM): Consensus standards for materials characterization and use; or another approved method. 10 Waste Sampling Methods Minn. R. 7045.0458, Subp. 2.C. requires a facility to address the sampling methods that will be used to obtain a representative sample of the waste to be analyzed. Samples may be taken from a variety of locations throughout the Facility or at an off -site location. Waste may be sampled from storage tanks, drums, roll -off boxes, and tankers, or from other locations including containment areas, process equipment, pipes, and pumps. The methods and equipment used for sampling vary with the type and consistency of the waste being sampled. To ensure samples and measurements are representative of the monitored activity, the appropriate sampling techniques, devices, containers, storage, shall be taken from 40 CFR 261 Appendix I or equivalent. Table 3: Waste Sampling Methods Waste Type Sampling Equipment General Procedure Non -Bulk Liquid Coliwasa or equivalent Composite sample from representative sample of drums. Non -Bulk Solid Scoop, Auger, Thief, Trowel Composite from 2 to 5 grabs. Non -Bulk Sludges or Various Use appropriate method, judgment Slurries required. Bulk Liquid (Tankers) Coliwasa or equivalent Composite from 2 to 5 grabs. Blended Liquids or Bulk Sampling port on tank Use sampling port to obtain sample Liquid in Tanks of blended waste. Sample collection will be in accordance with 40 CFR §261, Appendix I and facility SOPS. Page C -16 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator Samples will be labeled with a unique identifier upon collection. The sample label will contain the following information: Waste stream profile number, if available Load ID, if available Date of the sampling event An indication of any hazards associated with the sample Samples for metals, BTU, ash and total halogen analysis do not require preservation, and may be stored at room temperature for up to 6 months before analysis. Samples for other parameters will be preserved, stored and analyzed as specified by the analytical method. 11 Off -site Waste Analysis 40 CFR §264.13(b)(5) requires a facility to address waste analysis for off -site facilities. The incinerator consolidates shipments of some wastes for disposal at outside hazardous waste facilities. Analysis for treatment or disposal off -site is dependent upon the requirements of the off -site facility. Analysis will be performed as needed to meet those requirements. 12 Incinerator Waste Tracking System The 3M Corporate Incinerator has designed an inventory monitoring system, known as the Incinerator Waste Tracking System (IWTS), for waste identification and tracking. New waste stream profiles, along with any needed modifications to existing profiles, are transferred daily to the computerized IWTS database. This information is used for waste identification and verification. The IWTS provides operators with a system for tracking waste containers at the incinerator. During waste receipt, each waste container is assigned a unique load identification number and bar code. This bar coding system enables staff to track the movement of each hazardous waste container, and also allows staff to obtain necessary information contained in the waste stream profile for a particular load identification number. In addition to providing an inventory management system, the IWTS provides other operational controls. Some wastes received at the corporate incinerator are not treated on -site. These include PCB wastes and wastes for which the Land Disposal Restrictions require specific treatment technologies other than incineration. The WSP and IWTS programs have the capability of automatically assigning a DO NOT INCINERATE (DNI) flag on such wastes prior to processing that will prevent operators from managing these wastes inappropriately. The DNI flags can also be added to a waste stream profile by the Compliance staff. 13 Additional Waste Analysis Requirements Minn. R. 7045.0458, Subp. 2. requires a facility to address methods, where applicable, to address additional waste analysis requirements specified in: §264.17 Subpart B, General Requirements for ignitable, reactive, or incompatible waste. §264.314 Subpart N, Landfills, special requirements for bulk and containerized liquids. §264.341 Subpart O, Incinerators, waste analysis §264.1034(d) Subpart AA, Air Emission Standards for Process Vents, test methods. §264.1063(d) Subpart BB, Air Emission Standards for Equipment Leaks, test methods and procedures. §264.1083 Subpart CC, Air Emission Standards for tanks, surface impoundments, and containers. Page C -17 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator §268.7 Land Disposal Restrictions, testing, tracking, and recordkeeping requirements for generators, treatment, and disposal facilities. 3M will use the same procedures outlined in this WAP and the FAP to ensure waste analysis, where applicable, requirements are met on the above referenced regulations. 14 Quality Control Quality control for the analysis conducted in the Building 145 Laboratory will follow the measures outlined in the appropriate lab procedures. These laboratory methods are based on those specified in the latest edition of: U.S. EPA publication Test Method for Evaluating Solid Waste: Physical /Chemical Methods SW -846; Standard Methods for the Examination of Water and Wastewater; Methods for the Determination of Metals in Environmental Samples: EPA - 600/4 -91 -010; Methods for the Chemical Analysis of Water and Wastes: EPA - 600/4 -79 -020; American Society for Testing and Materials (ASTM): Consensus standards for materials characterization and use; or another approved method. Methods used by the laboratory include: Lab - Method -002, 'BTU Determination by Oxygen Bomb" Lab - Method -003, "Metals Determination by Inductively Coupled Plasma Optical Emission Spectroscopy (ICP -OES)" Lab - Method -004, 'Preparation of Samples for Dissolvable Metals Determination by ICP -OES" Lab - Method -005, "Percent Ash Determination" Lab - Method -006, "Total Chlorine Determination" Lab - Method -007, "Metals Determination by Energy Dispersive X -Ray Fluorescence" Lab - Method -008, "Total Fluoride Determination" For non 3M generators who supply analytical data, quality control data will be submitted with the analytical data as requested by 3M. 15 Recordkeeping The 3M Corporate Incinerator retains the results of all analyses performed on waste streams as a paper copy in its compliance files and /or in a computer database. These records will include raw data, calibrations, duplicate samples, matrix spikes, method blanks, lab control spikes, calibration verification, instrument blanks, and any other quality control data generated during analysis. Records shall be maintained for at least five (5) years after generation. This retention period would be extended for the duration of an unresolved enforcement action or by request of the Commissioner. 16 References 40CFR63.1209(c)(2) 40CFR63.8 (f) Air Emission Permit No. 16300025 -001 17 Revision History Written by Tina Galloway 09/16103. Revised 10/24/03 by Tina Galloway: Included chlorine in Table 3, Containerized Waste Feedstream Page C -18 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator Determination. Note: no changes required for Table 5, MACT Feedstream Determination Summary. Revised 05/13/04 by Tina Galloway: Added Appendix I, Waste Analysis Plan Summary. Appendix added to reduce redundancy with FAP and WAP requirements into one control document. Revised 07/30/04 by Tina Galloway: Added Mercury to Table 1, 2, and 5; clarified non - detect calculations for mercury on page 25 and 27. Revised 10/26/05 by Tina Galloway: Updated per new operating permits: Title V and RCRA. Also updated to include new procedure for sampling /analysis of bulk liquid waste due to new tank farm installation. Revised 12/9/05 by Tina Galloway: Updated to include reference of SW -846 test methods, included auxiliary fuel in bulk pumpable feedrate statistical determination, updated statistical model to reflect current practice and provide a brief description of it. Revised 10/11/2006 by Cindy Carlson: Updated to eliminate lengthy description of Facility operations. Reorganized information into more descriptive sections. Updated procedure for determination of metals concentrations in bulk liquid waste. Updated procedure for analysis of fuel oil. Updated procedure for verification testing by MVTL. Updated frequency of WSP verification testing. Removed references to a laboratory quality control plan. Minor wording changes to Attachment A. Revised 09/25/07 by Cindy Carlson: Updated bulk and non -bulk pumpable testing requirements, adding a requirement for metals testing before incineration. Added EPA method 6200 to list of tests performed. Revised 1/9/09 by Cindy Carlson: Clarified method of compliance with mercury feedrate limits as relating to fuel oil. Updated tables 1 and 2. Add additional reference to cylinders. Added guidance for testing and updating low- volume waste streams. Revised 12/16/09 by Cindy Carlson: Revised FAP and WAP to include procedures for testing and handling waste not generated by 3M. Other minor wording changes. Revision 11/9/11: FAP and WAP combined into one Plan. Extensive addition of detail regarding inspection, sampling, analysis. Page C -19 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator Table 4: Waste Review, Fingerprinting, and Analysis Matrix Waste Type Waste Stream Profile Acceptance Screening — Additional Analysis Verification Analysis Top 90% of waste streams by mass Bottom 10% waste streams by mass Analysis Fingerprinting Analysis Before Incineration 3M- Generator Certification Every Load — inspected and Blended -batch Every 5 Years: Sampled and analyzed These wastes will be included in the 100 waste Generated - lab analysis optional sampled sampled & analyzed: (7+ samples) for: ash, BTU, Cl, As, streams sampled and analyzed per year (with a Bulk Liquid 1) pH (aqueous only) <2, >12.5, BTU, %ash, %Cl, Be, Cr, Cd, Co, Ni, Ph, Hg preference for waste mixtures and wastes least three ranges between 2) physical As, Cd, Cr, Co, Ni, product -like wastes) for ash, BTU, Cl, As, Be, appearance 3) reactivity screen Pb Cr, Cd, Co, Ni, Ph, Hg 4 weight Non -3M- Lab Analysis required Every Load — inspected and Blended -batch Quarterly: Repeat of compositional Quarterly: Repeat of compositional analysis by Bulk Liquid - PCBs, BTU, Cl, As, sampled sampled & analyzed: analysis by generator generator Be, Cr, Cd, Co, Ni, Pb, Hg 1) pH (aqueous only) 12, >12.5, BTU, %ash, %Cl, - PCBs, BTU, Cl, As, Be, Cr, Cd, Co, - PCBs, BTU, Cl, As, Be, Cr, Cd, Co, Ni, Pb, Hg three ranges between 2) physical As, Cd, Cr, Co, Ni, Ni, Ph, Hg appearance 3) reactivity screen Pb Annually: Generator certification 4) weight Annually: Generator certification 3M- Generator Certification 100% of all containers of a Blended -batch Annual: Generator certification Annual: Generator certification Generated - lab analysis optional specific shipment— externally sampled & analyzed: Non -bulk inspected BTU, %ash, %CI, Every 5 Years: Sampled and These wastes will be included in the 100 waste Pumpable As, Cd, Cr, Co, Ni, analyzed (7+ samples) for: ash, BTU, streams sampled and analyzed per year (with a Liquids Pb Cl, As, Be, Cr, Cd, Co, Ni, Pb, Hg preference for waste mixtures and wastes least product -like wastes) for ash, BTU, Cl, As, Be, Cr, Cd, Co, Ni, Ph. Hg 3M- Generator Certification 100% of all containers of a None Annual: Generator certification Annual: Generator certification Generated - lab analysis optional specific shipment — externally Non- inspected Every 5 Years: Sampled and analyzed These wastes will be included in the 100 waste pumpable (7+ samples) for: ash, BTU, Cl, As, streams sampled and analyzed per year (with a wastes Be, Cr, Cd, Co, Ni, Pb, Hg preference for waste mixtures and wastes least product -like wastes) for ash, BTU, Cl, As, Be, Cr, Cd, Co, Ni, Pb, H 3M- Vendor Sampled and analyzed for 10° /a of all containers of a specific Blended -batch Annual: Generator certification Annual: Generator certification Shop Non- ash, BTU, Cl, As, Be, Cr, WSP per shipment— inspected sampled & analyzed: bulk Co, Ni, Pb and sampled BTU, %ash, %Cl, Every 5 Years: Sampled and analyzed These wastes will be included in the 100 waste Pumpable 1) pH (aqueous only) <2, >12.5, As, Cd, Cr, Co, Ni, (7+ samples) for: ash, BTU, Cl, As, streams sampled and analyzed per year (with a Liquids three ranges between 2) physical Pb Be, Cr, Cd, Co, Ni, Pb, Hg preference for waste mixtures and wastes least appearance 3) reactivity screen product-like wastes) for ash, BTU, Cl, As, Be, 4) weight Cr, Cd, Co, Ni, Pb, Hg Page C -20 of C -21 Section C - Waste and Feedstream Analysis Plan 3M Cottage Grove Corporate Incinerator 3M- Vendor Sampled and analyzed for 10% of all containers of a specific None Annual: Generator certification Annual: Generator certification Shop Non- ash, BTU, Cl, As, Be, Cr, WSP per shipment— inspected pumpable Co, Ni, Pb and sampled Every 5 Years: Sampled and analyzed These wastes will be included in the 100 waste Wastes 1) pH (aqueous only) <2, >12.5, (7+ samples) for: ash, BTU, Cl, As, streams sampled and analyzed per year (with a three ranges between 2) physical Be, Cr, Cd, Co, Ni, Pb, Hg preference for waste mixtures and wastes least appearance 3) reactivity screen - product -like wastes) for ash, BTU, Cl, As, Be, 4 weight Cr, Cd, Co, Ni, Pb, Hg Law Generator Certification Detailed packing slip None None None Enforcement Wastes 3M- Generator Certification 100% of all containers of a None None None Generated - lab analysis optional specific shipment — externally Wastes for inspected Traits- shipment 3M- Vendor Generator Knowledge 10 of all containers of a specific None None None Shop Wastes - lab analysis optional WSP per shipment — inspected for Trans- and sampled shipment 1) pH (aqueous only) <2, >12.5, three ranges between 2) physical appearance 3) reactivity screen 4 weight Auxiliary No. 2 Fuel Oil Tested None None No. 2 Fuel Oil sampled and analyzed No. 2 Fuel Oil sampled and analyzed annually Fuel (Fossil) approx.. monthly for 2 annually for BTU, Cl, S, ash, %water, for BTU, Cl, S, ash, %water, As, Be, Cd, Cr, Pb, years for BTU, Cl, S, ash, As, Be, Cd, Cr, Pb, Hg Hg %water, As, Be, Cd, Cr, Pb, Hg Natural Gas: vendor data or other published data. Sand for Tested during CPT to None None Sand for flux sampled and analyzed Sand for flux sampled and analyzed annually for Flux develop profile annually for As, Be, Cd, Cr, Pb, Hg As, Be, Cd, Cr, Pb, Hg Page C -21 of C -21 3M Section D 12/18/09 SECTION D SECURITY DA INTRODUCTION The information provided in this section is submitted in accordance with the requirements outlined by M.R. part 7045.0452, subpart 4. Security procedures and equipment in use at the 3M Cottage Grove site are described in the first section: General Site Security. Additional security measures at the incineration facility itself are detailed in the second section: Incineration Facility Security. D.2 GENERAL SITE SECURITY D.2.1 Perimeter Barriers The entire developed portion of the 3M Cottage Grove site is enclosed within a single seven - foot high, chain link fence topped by three strands of barbed wire. The main entrance to the plant is County Road 19 with a checkpoint at Building 65. This is normally the only entrance /exit to the plant. In an emergency, three other access points can be used for vehicular entrance or exit. These secondary entrances, shown in Figure P -1 of Appendix P, are located as follows: 1. Keats Road with gates at the railroad underpass. 2. Miller Road with a gate due north of Building 123. 3. Road to Cottage Grove Wastewater Treatment Plant which leads to 110 St. with a gate northwest of the former coal storage area. Two other gates in the perimeter fence access dead -end roads. These gates are also depicted on Figure P -1. The gate east of the wastewater treatment area is used to provide access to the Mississippi River for sampling purposes. Access to Production Wells 5 and 6 is provided by a gate located near Building 36. With the exception of the main entrance, which is continuously attended by 3M security guards, all gates are normally locked. D.2.2 24 Hour Surveillance System Security at the 3M Cottage Grove site is maintained by a staff of trained security guards who monitor entry and exit from the active portion of the facility, and provide security measures within the plant premises. D -1 3M Section D 12/18/09 The main security station, located in Building 65, is staffed with security personnel 24 hours a day, seven days a week. In addition to security staff, numerous CCTV cameras are also used to provide continuous 24 -hour surveillance and digital recording of the plant site and access roads from Building 65. D.2.3 Means to Control Entry All vehicles entering the plant are initially cleared through the Building 65 security center. Employees must use their 3M identification cards to activate an entrance gate, while contractors and other visitors must stop and register. Temporary daily passes are issued for each visitor to wear. When leaving the plant, each visitor must sign out and turn in the daily pass. As a rule, unnecessary vehicular traffic is not allowed within the plant property which is controlled by a second layer of interior perimeter fencing and two vehicle gates. After passing through Security, employees can enter the plant at five locations: 1. Building 116 lobby. 2. Building 41 east lobby. 3. 140 turnstile at the SE corner of the 116 employee parking lot. 4 72 turnstile at the SW corner of the 41 employee parking lot 5..Building 145 employee entrance The first four of these entrances have turnstiles operated by employee passes coded with electronic data. Building 145 has a door that is unlocked with an employee pass. These locations are monitored by CCTV from the security center in Building 65. Employees working in both Buildings 123 and the incinerator facility report directly to their work area where parking is provided for personal vehicles. The south - viewing Building 65 camera and the camera on the incinerator entrance gate are used to monitor traffic on the road to the incinerator. D.2.4 Security Procedures and Equipment In addition to the general security provisions of fencing, gates and guards discussed above, several other features contribute to the prevention of unknowing or unauthorized access to the facility. Ample lighting is provided throughout the site. Security personnel are equipped with hand -held, two -way radios for immediate reporting of abnormal conditions. In addition to the two -way portable radios carried by the guards, a base station for the public address system is located at the security center (Building 65). The internal telephone system for the plant is also used for external communications. D -2 3M Section D 12/18/09 D.2.5 Warning Signs Signs, legible from a distance of 25 feet, are posted at all fence gates in the incinerator area. These signs are visible from all angles of approach and bear the legend "Danger - All Unauthorized Personnel Keep Out." Also "No Smoking" signs, legible for a distance of 25 feet, have been placed at the plant and building entrances. D.3 INCINERATION FACILITY SECURITY D.3.1 Perimeter Barriers Within the 3M Cottage Grove site perimeter fence, the incinerator and its associated tanks, container and bulk storage areas are enclosed with a second seven -foot high, chain link fence topped by three strands of barbed wire. Three gates are provided for access. The main gate is activated using a pass issued by site Security. A second gate has been provided for vehicular access to the Containment Building. The third gate, located northwest of the former coal storage area, is provided as an emergency exit. Figure P -1 shows the location of the incinerator barriers. D.3.2 24 Hour Surveillance System In addition to the 24 hour surveillance provided by 3M Cottage Grove security personnel, television monitors in the Incinerator Control Room provide 24 hour surveillance of incineration facility entrances, storage areas and process areas. Video monitors in the Incinerator Control Room pan the main gate area in order to monitor incoming and outgoing waste shipments, and provide 24 hour surveillance of key process and storage areas. D.3.3 Means to Control Entry All 3M employees, contractors and visitors pass through an initial security check at the Building 65 Security Center on entering the site. Contractors and visitors sign -in as outlined above before proceeding to the incineration facility. Employees, contractors and visitors enter the incinerator facility through an entrance lobby in the Building 145 office complex. From the lobby, a locked door with an opener activated by the electronic code in the employee identification badges provides entry to the facility. Visitors and contractors are required to sign the incinerator log book. D -3 3M Section D 12/18/09 D.3.4 Security Procedures and Equipment In addition to the general site security provisions and the incineration facility security provisions discussed above, several other features contribute to the prevention of unauthorized entry to the facility. Daily inspection of active waste handling areas supplements the continuous surveillance of these areas via the television monitors in the incinerator control room. The structural integrity of the perimeter fence and security gates are inspected monthly. Nightly and weekend foot and vehicle patrols of the area are conducted by site security. The two way radios and telephones that provide security communications are used daily. For a description of the incineration facility inspection program, see Section E. D.3.5 Warning Signs Signs, legible from a distance of 25 feet, are posted at all access gates as well as on the perimeter fencing around the incineration facility. These signs are visible from all angles of approach and bear the legend "Danger - All Unauthorized Personnel Keep Out." "No Smoking" signs are posted at the appropriate locations in all areas of the facility. D -4 3M Section E 12/18/09 SECTION E INSPECTIONS EA INTRODUCTION Scheduled inspections of the hazardous waste treatment and storage facilities at the 3M Cottage Grove Center are conducted to identify equipment malfunctions, structural deterioration, operator errors, and discharges that could cause or lead to the release of hazardous waste constituents and adversely affect the environment or threaten human health. This program of scheduled inspections is in accordance with the requirements stipulated in 7045.0452, subpart 5: General Inspection Requirements. Table E -1 presents a general summary of the facility inspection, calibration, and maintenance program. Inspections are conducted in accordance with the facility inspection schedule, which is maintained as part of the standard operating procedure for inspections in the facility's Standard Operating Procedures Manual. Information about the preventive maintenance and calibration program for critical instrumentation is maintained in the facility's Operations and Maintenance Manual. Documentation of inspections, calibrations, and maintenance is maintained at the facility. E.2 PERSONNEL RESPONSIBILITIES Portions of the facility inspections are routinely conducted by individuals filling the following positions: • Incinerator Shift Supervisor • Incinerator Process Operator (PO2) • Incinerator Control Room Operator (POI) • Shipping and Receiving Operator • Systems Control Technician The Incinerator Process Operator inspects all process equipment mechanical components, safety and emergency equipment, and facility security devices. The Shipping and Receiving Operator or Incinerator Process Operator inspects the tank farm, container storage in Buildings 47, 60 and 145 (including dock area), container storage in Buildings 77 and 136, Containment Building 181, and all trailer storage areas. The Incinerator Control Room Operator is responsible for inspecting process monitoring parameters displayed in the Control Room. Inspection of these parameters is conducted to spot trends indicating that equipment maintenance may be required. The Incinerator Control Room Operator is also responsible for verifying the operability of the waste feed cutoff system and associated process alarms weekly. E -1 3M Section E 12/18/09 Table E -1 Inspection and Maintenance Program Summary E -2 3M Section E 12/18/09 Equipment/P Key Ins pection and Maintenan C I --Maint and Inspection Fre - Monitoring and - e ration - E ui merit Em S stems :- Calibrat Ins pection Service Ala rms :! Waste Cutoff Container storage areas Containers Leaks, labeling, location, access Leaks, liquid in dikes Daily Weekly (a) (a) Tanks, pumps, piping Leaks, secondary containment - Daily (a) - - Tank overfill controls Proper operation and accuracy - Daily (a) Weekly - Ash handling equipment Mechanical problems, ash spills - Daily (a) - - Security Areas secured - Daily (a) - Safety and emergency equipment Availability, location - Daily (a) - Alarms Proper operation and accuracy Daily (a) Weekly Hazardous Waste Feed Cutoff Proper operation and accuracy Per permit requirements or manufacturers recommendations - Per prescribed schedule (a) Per prescribed schedule - Per prescribed schedule Weekly Per prescribed schedule Process instrumentation Per prescribed schedule E -3 3M Section E 12/18/09 (a) Equipment manufacturer's recommendation E -4 3M Section E 12/18/09 The Systems Control Technician is responsible for inspecting field process monitoring instrumentation. Items inspected by the Systems Control Technician include the CEM systems, pH probes, thermocouples, pyrometers, level gauges, and pressure sensors. The Incinerator Shift Supervisor is responsible for reviewing all inspection logs and may also perform site inspections. Facility inspections are daily, seven days a week. On weekends, a Systems Control Technician from the Plant Maintenance personnel pool conducts inspections normally performed by the Systems Control Technician assigned to the incineration facility. Contractors who have received the appropriate training may also conduct inspections of designated areas on an as- needed basis. E.3 INSPECTION SCHEDULE Table E -1 is a summary of facility inspection schedule. The detailed inspection schedule is maintained as part of the incinerator facility's standard operation procedures for inspection. The inspection schedule lists items to be inspected on an area by area basis and is organized to facilitate inspection rounds. The schedule also identifies the types of problems looked for, normal operating conditions, the frequency of inspection for each item, and the specific personnel performing each inspection. The inspection schedule describes inspection requirements for the following categories of equipment: • Container storage areas: Buildings 47, 60 and 145 Buildings 77 & 136 Drum Storage Lots & Trailers • Pump room (Bldg 47) and sludge room (Bldg 145) equipment • Containment Building 181 • Tank storage areas • Incineration equipment • Ash handling equipment • Air pollution control system • Neutralization system • Continuous emissions monitoring system (CEM) • Security devices • Safety and emergency equipment E -5 3M Section E 12/18/09 • Control room monitoring equipment • Process field instruments. E.4 INSPECTION PROCEDURES A brief description of procedures for inspecting major categories of items is presented below. E.4.1 Container Storage Areas Containers are stored in Building 47, Building 60, Building 145, Building 77, and Building 136. The location of each building is depicted on Drawing No. CHEM- 888 -C -142 in Appendix A. In addition, containers are stored on trailers parked at the dock stalls in Building 47, Building 60 and Building 145. The procedure for inspecting container storage areas in Buildings 47, 60 and 145 involves walking throughout each of the buildings and evaluating the condition (structural integrity, seals, labels) and proper placement of ignitable, reactive, or incompatible waste containers. The inspection should confirm that storage practices (stacking height, aisle space) meet the National Fire Protection Association (NFPA) flammable and combustible liquids code requirements. These requirements are incorporated by reference into OSHA standards (29 CFR 1910.106). Secondary containment is inspected for structural integrity and the presence of any liquid accumulation. Containers may be also stored on trailers in permitted container storage lots. The location of these lots is depicted on Drawing No. CHEM- 888 -C -142 in Appendix A. Once per week, all the individual trailers in every permitted trailer storage lot are inspected for container integrity and evidence of leakage. Secondary containment liners are installed in those trailers used to store liquid hazardous waste. Additionally, 10% of the storage trailers are inspected weekly on a rotating basis for structural integrity of the trailer, condition of the trailer liner, slope of the trailer and trailer location. In addition, the conditions of the storage area secondary containment systems are noted. For Lots A, C and D, the dike drainage valve is checked to verify that it is closed. The quantity and quality of accumulated precipitation is also checked to see if drainage is required or if a leak is evident. Inspection of Lot M involves noting the water level and quality in the runoff pond. In addition to weekly inspections, trailer storage lots are inspected routinely after significant rainfall to determine if drainage is required. E -6 3M Section E 12/18/09 E.4.2 Sludge Room Equipment Both floor levels of the Sludge Room in Building 145 are inspected daily. Piping, valves, fittings and seals are visually inspected for signs for leakage or deterioration. Screens are checked for clogging, unusual noise is noted as an indicator of potential bearing or balance problems, and the sludge tank recirculation pump is inspected for proper operation. The sludge tanks are also inspected daily for indications of deterioration and /or leakage. Tank level indicators are calibrated according to the Preventative Maintenance schedule and levels are monitored daily in the control room. The Pump Room located in Building 47 is inspected daily when in use for handling or storing wastes. Any containers present in the sludge room or direct burn room in Building 145 and the pump room in Building 47 are inspected according to the container storage procedure outlined above in Section E.4.1. E.4.3 Containment Building Containment Building 181 is inspected daily. Proper storage of any bulk waste is verified, and the condition of the floor is checked. E.4.4 Tank Farm and Blend Tank Area Storage Tanks All waste storage tanks, other than Tank 1, are located above ground and are easily accessible to facilitate thorough inspections. The procedure for inspecting storage tanks involves visually examining each tank and its associated piping, connections, valves, etc., for indications of deterioration and /or leakage. Tank agitators are checked for unusual noises. Tank overfill indicators are calibrated according to the Preventative Maintenance schedule and levels are monitored in the control room. Waste storage tanks are also inspected annually for any defect that could result in air pollution emissions. Tank 1 is an on -grade tank with a double bottom. The design of the system provides for daily inspection of the double bottom and the secondary containment by visual methods. In addition to the tanks themselves, secondary containment areas are examined for general integrity and evidence of tank leakage. Any liquids in secondary containment areas are removed within 24 hours. The dike drainage valve is checked to ensure that it is in the normally closed position. Pumps and piping associated with the tank farm are inspected daily. E -7 3M Section E 12/18/09 E.4.5 Building 77 Building 77 is located adjacent to the fuel oil unloading area. Any liquids in the secondary containment area are removed within 24 hours. The dike area has total containment consisting of trenches and a sump with no outlet. Non - contaminated storm water is removed by a vacuum truck and discharged into the wastewater system through the neutralization pit. Contaminated storm water is placed in drums and burned in the incinerator. , Any containers present in Building 77 are inspected according to the container storage procedure outlined above in Section E.4.1. E.4.6 Tanker Unloading Building Secondary containment areas for the Tanker Unloading Building 136, are examined for general integrity and evidence of tanker leakage. Any liquids in the secondary containment area are removed immediately. The dike area has total containment consisting of trenches and a sump with no outlet and the area is covered to prevent surface run -on. , Any containers present in the Building 136 are inspected according to the container storage procedure outlined above in Section E.4.1. E.4.7 Komar Shredder Inspection of the Komar Shredder area mechanical equipment is conducted daily. These inspections include instrumentation devices that have local readings and the following major and ancillary process equipment: • Komar processor hydraulic and grease purge systems, • CO fire suppression system, • Primary and secondary nitrogen purge systems (including 0 analyzers) for pallet and drum pre- chambers drop chamber, and • Drop chamber relief panels. E.4.8 Incinerator Inspection of the incineration area mechanical equipment is conducted daily. These inspections include instrumentation devices that have local readings and the following major and ancillary process equipment: burners, drum feeder hydraulic system, air compressors and dryers, therminol frontwall and sludge lance cooling systems, primary air fan, frontwall and secondary combustion chamber burner combustion air fans, kiln end cooling fan, kiln drive, kiln plenum, and the front and back kiln seals.. An inspection of the kiln refractory is conducted at least annually as part of a scheduled preventive maintenance procedure. E.4.9 Ash Handling System E -8 3M Section E 12/18/09 Inspection of the ash handling area mechanical equipment is conducted daily. These inspections include instrumentation devices that have local readings and the following major and ancillary process equipment: ash quench tank, ash conveyor, and ash quench sump. The ash trucks are also inspected daily. E.4.10 Air Pollution Control System Inspection of the air pollution control system mechanical equipment is conducted daily. These inspections include instrumentation devices that have local readings and the following major and ancillary process equipment: recycle and seal tanks, recycle pumps, WESP controller, cooling system chemical feed tanks, and the ID fan. The cooling tower area is also inspected daily. Cooling tower inspection includes instrumentation devices that have local readings and the following major and ancillary process equipment: cold sump, cooling tower pumps, sulfuric acid tank and secondary containment area. E.4.11 Neutralization System Neutralization system mechanical equipment is inspected daily. These inspections included instrumentation devices that have local readings and the following major and ancillary process equipment: lime feed system, caustic storage tank, caustic feed pump, polymer feed system, neutralization pit and pit screen, and lift station pumps.., The lime silo is inspected for structural integrity. E.4.12 Continuous Emissions Monitoring Equipment The CEM's are inspected daily for the following items: • Gas flow rate • Vacuum pressure • Potentiometer settings • Gas conditioning system air infiltration • Gas conditioning system moisture dropout efficiency • Electronics hardware operation • Acceptable readings In addition to routine inspections, the CEM system is calibrated in accordance with vendor specifications on a daily basis. All CEM inspections and instrument calibrations are conducted by a Systems Control Technician. E -9 3M Section E 12/18/09 Contractors who have the appropriate training may conduct instrument inspections and calibrations as needed. E.4.13 Security Devices All communications equipment including telephones and two -way radios are used daily and maintained in proper working condition. Security fence and gates are inspected for structural integrity and warning signs are checked for legibility according to the procedures outlined in Section D. E.4.14 Safety and Emergency Equipment Routine safety and emergency equipment inspection is performed on a monthly basis under the Monthly Safety Inspection standard operating procedure maintained in the facility's Standard Operating Procedures Manual. Fire control equipment is inspected for operability and content of fire retardant chemicals (foam, inert gas, dry chemical, water, etc.). Spill control and safety equipment (breathing equipment and protective clothing) are inspected for operability and integrity. Emergency showers and eyewash stations, alarms, and communication equipment are also inspected. Safety and emergency devices are inspected for the following: • Adequate quantities of supplies • Operability • Suitable for the application Records of monthly safety and emergency equipment inspections are maintained at the facility. In addition to monthly inspections, the location of spill carts and fire extinguishers are also routinely checked. Plant emergency lighting is inspected monthly as part of the facility's preventive maintenance program. The plant fire protection system is inspected semi - annually by an independent contractor. E.4.15 Control Room Monitoring Equipment The Incinerator Control Room Operator is responsible for daily verification of the performance of process instrumentation in the Control room area. Principal inspections include those for waste feed cutoffs, alarms, the emergency shutdown interlock system, and process control parameters (temperature, pressure, tank level, etc.). In addition to the inspection log, the Incinerator Control Room Operator also completes a Daily Operating Log. E -10 3M Section E 12/18/09 The emergency hazardous waste feed cutoff ( HWFCO) system is tested at least weekly to verify operability unless the HWFCO has been tripped by normal operation within that week. The Control Operator's continual observation of process parameters verifies the functioning of individual waste feed cutoffs. Process alarms are monitored by the Control Room Operator via a computer terminal that constantly displays current alarms,critical alarms are electronically recorded. The Control Room Operator verifies monthly that the Emergency Stack has opened as programmed during either an emergency or controlled shutdown. If no shutdown has occurred during the month, the operator tests the Emergency Stack using the Emergency Stop push button after the waste feeds have been stopped and the burnout period has elapsed. E.4.16 Process Field Instruments Process monitoring instrumentation with local readings is checked daily as part of the routine inspection of the various process areas and is inspected and calibrated on a regularly scheduled basis by a Systems Control Technician. These devices include continuous emissions, flow, level, temperature, pressure, 02 concentration, and pH measuring and control instruments. Routine calibrations performed under the facility's Preventive Maintenance program are also documented in the computerized preventive maintenance program and in the instrumentation file maintained for each continuous monitor. Contractors who have been properly trained may also perform process filed instrumentation inspection and calibration as needed. E.6 REMEDIAL ACTION Inspectors note any abnormal condition or conditions that require action in the Remedial Action section of the Daily Operating Log. The Incinerator Shift Supervisors review the inspection and Daily Operating logs each day and schedule any required maintenance through plant maintenance services. Corrective maintenance procedures are initiated as a result of inspections performed by the various inspectors. If inspections reveal that non - emergency maintenance is needed, repairs are completed as soon as possible to preclude further damage and reduce the need for emergency repairs. If a hazard is imminent or has already occurred during the course of an inspection or at any time between inspections, remedial action will be taken immediately. 3M personnel will notify the appropriate authorities per the Contingency Plan, if required, and initiate remedial actions. In the E -11 3M Section E 12/18/09 event of an emergency involving the release of hazardous constituents to the environment, efforts will be directed toward containing the hazard, negating it, and subsequently decontaminating the affected area(s). Procedures described in the facility Contingency Plan provide additional details on procedures to be taken in response to spills, releases, or emergencies. E.6 RECORD KEEPING The Daily Rounds Log, Storage Lots and Trailers Weekly Checklist, and Instrumentation Inspection Log are used to record the results of daily, weekly, and monthly inspections. Information that must be recorded on the inspection log sheets includes the inspector's initials, date of inspection, item(s) inspected, and status of the item(s). The Remedial Action section of the Daily Operating Log provides space for noting pertinent observations and corrective action requirements. All active inspection logs are stored in the Control Room or in an area designated by the Supervisor. At the end of each month, the inspection logs and the Daily Operating Log are forwarded to the Compliance Files where they are retained for five (5) years. Safety and emergency equipment inspection logs are also filed in the Compliance Office when complete. Calibration records (daily, weekly, monthly, quarterly, semi - annual, and annual) are completed by the Systems Control Technician and retained in the Compliance files for five (5) years. E -12 3M Section F 12/18/09 SECTION F PREPAREDNESS AND PREVENTION FA INTRODUCTION The information provided in this section is submitted in accordance with the requirements outlined by M.R. part 7045.0462, Preparedness and Prevention. F.2 DESIGN AND CONSTRUCTION OF THE FACILITY All on -site oil and hazardous materials storage tanks are equipped with secondary containment (concrete treated with a chemical resistant coating, except for Tank 1, which has steel secondary containment). The secondary containment areas are large enough to contain the entire contents of the largest tank plus sufficient freeboard to allow for precipitation. Capacity of secondary containment for storage tanks is detailed in Section S2. All tanks are equipped with high level alarms and electronic gauges. Tank levels are continuously monitored from the Incinerator Control Room. All secondary containment areas are inspected daily. The location of trailer storage lots is shown on Drawing No. CHEM- 888 -C -142 in Appendix A and discussed in Section S1. Regulated waste oil and oil products, are stored in the hazardous waste trailer storage lots. All trailer storage lots and secondary containment systems are inspected weekly. In addition, the interior of the trailer is inspected weekly for leaking or deteriorating containers and deterioration of the containment liner within the trailer. Containers with liquids are stored in hazardous waste storage trailers equipped with metal liners designed to collect any leaks from containers I These trailers are stored in the north half of Lot A, and Lots B, D, E, F, K, and L. Both lined and unlined trailers are used in the south half of Lot A and Lot C which are concrete and have secondary containment. The design of this containment system is discussed in detail in Section S1. The combination of liners and secondary containment combined with water - resistant trailer end gates, ramps, sloped trailers, or graded storage areas provide the required secondary containment. Lots L and M not used for hazardous waste storage. Buildings 47, 60, and 145 have been designed and constructed to meet or exceed local, state and 3M fire, safety and health standards. All waste drums are handled in areas that are equipped with curbed or sloped impermeable surfaces. Floor drains in areas where hazardous wastes are handled in Buildings 47 and 60 discharge to dead end sumps or Tank 3, a 12,900 F -1 3M Section F 12/18/09 gallon tank. Floor drains in Building 145 waste processing areas drain through a 390 gallon vertical sump to a 12,000 gallon underground containment tank. Some hazardous waste materials that require special handling are stored in the rear of Building 60. Incompatible wastes are segregated in this area by distance and by a system of curbs and trenches. Trenches in this area are divided to eliminate the possibility that spilled incompatible wastes could mix in the floor drains. Drums are inspected daily for leaks and damage. All incinerator operations staff are trained to respond properly to hazardous material spills and leaks. Small spills are promptly cleaned up, and residues disposed of in the incinerator or at another permitted treatment, storage or disposal (TSD) facility. Larger spills would be contained by curbing and dead end sumps or the Building 145 containment tank. Residues are promptly removed from sumps or the containment tank after a spill. Ventilation in areas in Buildings 47, 60 and 145 where waste containers are opened (pump room, sludge room, direct burn room, pak feeder de- lidding station and Building 60 sampling station) meets or exceeds NFPA standards for Class I, Division I areas, assuring that explosive levels of vapors do not accumulate. The electrical wiring in these areas meets Class I, Division I standards. Ventilation in other process areas of Buildings 47, 60 and 145 (excluding office space) meets or exceeds NFPA standards for Class I, Division II areas. The electrical wiring in these areas also meets Class I Division 11 standards. The stairways in the area of the incinerator are under positive pressure, thus preventing the accumulation of vapors in stairwells. The floor inside the Bldg. 136 tanker unloading station is sloped away from all doors and has a sump with a 10,000 gallon capacity. The capacity of the largest tanker to use the facility is 7,000 gallons. Bldg. 77 can also be used to unload tankers. This area is equipped with an impermeable surface and a sump that can hold up to 8,000 gallons. This sump also services the adjacent drum handling facility. Secondary containment is provided for chemical feed tanks associated with the cooling water system. Fixed light water/ water deluge fire protection systems are located in the process and waste handling areas of Buildings 47, 60 and 145. A fixed CO fire suppression system is installed on the first floor of Building 145 provides fire suppression for the interior chambers of the Komar processor. F -2 3M Section F 12/18/09 F.3 MAINTENANCE AND OPERATION OF THE FACILITY The program of routine inspection of waste containers, waste storage areas, process equipment and instrumentation and safety equipment serves both to prevent and to minimize the effects of a fire, explosion, or any unplanned release to air, land or water of hazardous waste. The computerized waste inventory system provides both the ability to track each waste container from the time it is received at the incinerator until its ultimate disposal and immediate access to information about the waste stream constituents in any waste container. This significantly decreases the potential for incompatible waste to be stored together and allows the Process Control Operators to dispose of each container safely, properly and efficiently. FA REQUIRED EQUIPMENT 3M Cottage Grove Center maintains an internal communications and alarm system capable of providing immediate emergency instruction by both voice and signal to incinerator personal. Details of the incinerator facility's emergency equipment, communication and evacuation alarms are available in the incinerator facility's Emergency Response Guide, incorporated into the Integrated Contingency Plan. Telephones used to contact 3M Cottage Grove Security for emergency assistance are located in the incinerator's Control Room, Supervisor's Office, Shipping and Receiving Office, Tanker Unloading Station and at various other locations throughout the facility. Workers making inspections of the hazardous waste trailer storage areas or other process areas are equipped with two -way radios and are in contact with the Control Room. Portable fire extinguishers and fire control equipment, spill control equipment and decontamination equipment are available at appropriate locations throughout the facility. 3M Cottage Grove Center has a fire water system independent of its plant supply water system. The system is described in section II, 2.d (2.2) of the site's Integrated Contingency Plan. F.5 TESTING AND MAINTENANCE OF EQUIPMENT Fire control equipment is inspected periodically as part of the incinerator's general inspections program. Spill cleanup equipment is restocked as used so that cleanup carts and cabinets maintain a proper inventory of supplies. F -3 3M Section F 12/18/09 F.6 ACCESS TO COMMUNICATION /ALARM SYSTEM All process areas are equipped with evacuation alarms that can be activated by operating personnel. Key telephones are located in the incinerator's Control Room, Supervisor's Office, Shipping and Receiving Office and Tanker Unloading Station. In addition, the control room operator constantly monitors key process areas via remote video and can summon external emergency assistance promptly. Two -way radios are used during inspections of external incinerator areas including the trailer storage lots and storage tanks. Emergency assistance from local police, fire and emergency response squads can be summoned at all times from the scene of operations. Standing arrangements with local emergency response units are detailed in Section 2 of the 3M Cottage Grove Center Integrated Contingency Plan. F.7 AISLE SPACE Waste containers are normally stored on pallets to minimize contact with an accidental discharge. Adequate aisle widths are maintained to allow for clear inspections of all containers. Aisle widths are maintained within the containment trailers by placing the drums on pallets stacked down the center of the trailer allowing inspection of either side of the pallets. F -4 3M Section G 12/18/09 SECTION G CONTINGENCY PLAN GA GENERAL REQUIREMENTS The 3M Cottage Grove Center Integrated Contingency Plan has been prepared and is kept updated as needed. The Contingency Plan has been designed to meet the provisions of M.R. part 7045.0466 Subparts 2 to 6, parts 7045.0464, 7045.0468 and 7045.0470. It is designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non - sudden release of hazardous waste or hazardous waste constituents to air, land or water. G.2 IMPLEMENTATION OF THE CONTINGENCY PLAN The provisions of the plan would be carried out immediately if a fire, explosion, or release of hazardous waste or hazardous constituents threatens human health or the environment. G.3 CONTENT OF THE CONTINGENCY PLAN The site Integrated Contingency Plan addresses overall emergency response requirements from a site perspective. Details specific to the Incinerator operation are in the appendix to the site Emergency Response Guide, part of the site Integrated Contingency Plan. The plan includes: • Purpose and Scope • Core Plan Elements, including discovery, notification, sustained action and follow -up • Facility and Locality Information • Notification • Response Management System • Incident Documentation • Training and Exercises /Drills • Response Critique • Prevention • Regulatory Compliance and Cross - Reference Matrix • Shelter -in -Place Procedures • Business Continuity Plan • Public Communications Plan • 112(r) Hazard Assessment • Oil Pollution Act of 1990 G -1 3M Section G 12/18/09 • Emergency Response Checklists • Emergency Response Guide GA COPIES OF THE CONTINGENCY PLAN Copies of the site Integrated Contingency Plan are maintained at 3M Cottage Grove Center by the Site Environmental Manager; and have been submitted to state and local authorities as required. G -2 3M Section H 12/18/09 SECTION H PREVENTIVE PROCEDURES, STRUCTURES AND EQUIPMENT H.1 INTRODUCTION The facility maintains procedures, structures and equipment to prevent or mitigate the following conditions, outlined in M.R. Part 7001.0560, sub section H. Additional preventive procedures are discussed in Section F (Preparedness and Prevention) of this document. H.2 PREVENTION OF HAZARDS IN LOADING /UNLOADING OPERATIONS Unloading operations take place at the dock areas and drum handling areas of Buildings 47, 60, 77, 145 and 136 . In the event of an accidental release, spilled materials will be contained within spill containment structures or with an absorbent product. Spill cabinets are located in close proximity to loading docks. Several precautions have been taken to reduce the potential for hazards during loading /unloading operations in Buildings 47, 60 and 145. Off -load ramps are constructed to facilitate movement of a forklift truck in and out of storage trailers„ adequate aisle space is maintained at all times, and trailer wheels are chocked and dolly braces are placed underneath the front of the trailer for support in the event of a leg failure. The docks are also equipped with dock locks and lighting. The unloading of bulk shipments of liquid waste at the incinerator tank farm has also been safeguarded in numerous ways. All of the 18,390 gallon storage tanks and Tank 1 are located within secondary containment. All tanks used for hazardous waste storage have continuous readout level indicators and are equipped with high level alarms. The output for these indicators is displayed in the incinerator control room. A 12,900 gallon tank (Tank 3A) is used as an overflow tank for the building 47 pump room. This tank, is normally left empty, a low level (25% full) alarm on the tank is used to alert the incinerator operators that an overflow condition exists. When a tank truck arrives for unloading at the Tanker Unloading Station, one of the waste storage tanks is selected to receive the waste based on the levels of the tanks, material compatibility and intended disposal method. An operator supervises the unloading procedure from beginning to end. Process alarms with audible and visual feedback in the Tanker Unloading Station alert the operator to high level in the tank being filled . The unloading area is paved and diked and drains to a concrete sump. H -1 3M Section H 12/18/09 Spill containment supplies and fire extinguishers are kept in close proximity to the tanker unloading station. In addition, all incinerator operators receive Spill Prevention Control and Countermeasures training. H.3 PREVENTION OF RUNOFF Containers at the facility are stored on truck trailers in permitted waste storage areas. Lot D and the north half of Lot A are clay - lined, containment areas used for the storage of regulated hazardous waste. The south half of Lot A has a concrete secondary containment system coated with a chemically resistant coating or equivalent. Runoff from each storage area is drained by design to one corner of the storage pad where a valve is used to control the discharge. The drainage valve is opened to drain accumulated stormwater, but only when routine inspections of the area have not revealed any accidental discharges, and a visual inspection of the accumulated water reveals no contamination. As soon as drainage is complete, the valve is returned to its normal closed position. Lot M is constructed using 8 inches of class 5 crushed rock. Runoff from Lot M is collected in an existing run -off pond. Lot C and the south half of Lot A are paved storage areas used to store wastes prior to receipt at the incinerator facility. These provide concrete secondary containment and are coated with a chemically resistant coating. . Lots B, K, and L are constructed with clay and synthetic liner systems. These lots are also bermed to contain run -off and spills and to prevent run -on. Lots E, F, and M are not lined and constructed of class 5 crushed rock. Lot M is used to store non - regulated waste only Secondary containment is provided by internal secondary containment in the storage trailers. Several of the lots have 8 ft. wide concrete strips that are used to support the front dolly trailer supports. Lot J is a clay -lined area used for the storage of non - regulated waste. Runoff from this area is collected in a holding pond. Discharge from the holding pond is only allowed when routine inspections of the area have not revealed any accidental discharges and a visual inspection of the accumulated water reveals no contamination. The accumulated water can be pumped to either the cooling water pond or the wastewater treatment area The bulk waste handling areas at the incinerator, containment Bldg. 181 and the ash house, are located within buildings, thereby precluding the possibility of precipitation run -on. Run -off from these areas is prevented through the use of drains, floor slope, or concrete berms. For location of trailer storage lots, see Drawing No. CHEM- 888 -C -142 in Appendix A. H -2 3M Section H 12/18/09 H.4 PREVENTION OF CONTAMINATION OF WATER SUPPLIES Groundwater and surface water contamination are eliminated by preventing the discharge of hazardous materials onto unprotected ground. Any accidental discharges that occur are promptly cleaned up. Runoff to the water supply is prevented by the procedures outlined above in section H.3. All water used in process operations is sent to the wastewater treatment system to remove contamination. Water from pollution control equipment is drained through the mix box into the neutralization system. After pre- treatment with lime, caustic, and polymer in the neutralization system, the water is pumped to the site's wastewater treatment plant. Water from the quenches used to cool kiln ash is treated in the same manner. Backflow preventers installed in the water lines prevent the contamination of water sources. H.6 MITIGATION OF EFFECTS OF EQUIPMENT AND POWER FAILURE The effects of equipment failure are minimized by the close and continuous monitoring of essential equipment provided by the automated control systems operating at the incinerator. In addition to providing incinerator personnel with constant feedback from the process, the systems provide appropriate process responses such as waste feed cut off or incinerator shutdown in the event of the failure of essential pieces of equipment. In the event of an unanticipated power interruption, the incinerator goes through an automatic shutdown procedure designed to protect both workers and equipment . Equipment and lighting essential for a safe shutdown has backup power from an emergency generator. The computer systems providing process monitoring, control and data collection are powered by an un- interruptible power system (UPS). Once power is restored, there is a standard operating procedure for recovery from power loss.. H.6 PROTECTION OF PERSONNEL FROM EXPOSURE TO HAZARDOUS WASTE Incinerator operators are protected from exposure to hazardous waste through proper ventilation (primary control) and the use of protective equipment (secondary control). Process areas where waste containers are opened are equipped with ventilation systems meeting or exceeding the NFPA requirements for Class I, Division I areas. Other areas in Buildings 47, 60 and 145 where waste containers are handled have a ventilation system meeting or exceeding NFPA requirements for Class I, Division II areas. Proper ventilation prevents the accumulation of high concentrations of hazardous constituents in these areas. H -3 3M Section H 12/18/09 Incinerator operators are also protected from exposure to hazardous waste through the proper use of protective equipment. A member of the incinerator health and safety staff evaluates each waste stream profile accepted for handling at the incinerator and determines the appropriate protective equipment for that waste. All operators are provided with washable uniforms. In addition, at a minimum, each operator is required to wear safety glasses and conductive footwear. Ear protection and chemically resistant bibs and gloves are also used in designated areas. Additional protective equipment may be specified for individual waste streams or waste processing areas. This equipment includes: full /face waste respirator with appropriate cartridge (i.e. organic vapor /acid gas, formaldehyde, etc. with HEPA pre - filter for particulate control); self contained breathing apparatus; nitrile, neoprene or rubber gloves boots, and paper- coated Tyvex or rubber coveralls. SCBA's are also available. Operators receive periodic training in the use of protective equipment. H.7 PREVENTION OF RELEASES TO ATMOSPHERE Releases to the atmosphere from the Incinerator combustion process are controlled by maintaining a negative pressure in the system. Fugitive emissions from all aspects of the rest of the operation are subject to compliance with MR part 7011.7400. H -4 3M Section 1 12/18/09 SECTION I PREVENTION OF REACTION OF IGNITABLE, CORROSIVE, REACTIVE AND INCOMPATIBLE WASTES 1.1 INTRODUCTION Accidental ignition and reactions of incompatible wastes are prevented through: (1) proper waste classification and labeling, (2) segregation during storage, (3) proper handling of materials in designated areas, and (4) compatibility testing. As required by M.R. Part 7045.0456, these procedures prevent reactions that generate extreme heat, pressure, fire or explosions; produce uncontrolled toxic mists, fumes, dusts or gases in sufficient quantities to threaten human health or the environment; or create uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosion. 1.2 PROPER WASTE CLASSIFICATION AND LABELING All waste materials received at the 3M Corporate Incinerator are properly labeled and packaged in containers that are compatible with the waste. Proper labeling includes a waste stream profile number as discussed in Section C. A waste stream profile describes the constituent components of the waste stream, hazard information, regulatory classifications for DOT, OSHA, and RCRA, container specifications, required labels and information about the generator. Each waste stream profile must be approved prior to the acceptance of any waste containers for that profile at the incinerator facility. Information in a waste stream profile is used to generate protective equipment/clothing codes and storage and handling codes. When waste is received, each container is given a unique bar -coded load ID generated by the facility's computerized waste tracking system (IWTS). This barcode label provides incinerator personnel access via handheld terminals to safety, storage and process information about each waste container and facilitates proper segregation and handling of waste. 1.3 SEGREGATION DURING STORAGE Containers are segregated during storage to prevent reactions of ignitable, corrosive, or incompatible wastes. Segregation and separation of each hazardous waste will be consistent with the 49 CFR Subp. C, Segregation and Separation Chart of Hazardous Materials (177.848). Containers are normally stored on pallets to minimize contact with accidental discharges. Containers are stacked no more than two containers high. Adequate aisle widths are maintained to minimize the risk of a forklift's scraping or puncturing a container and to provide for easy inspection of containers. 1 -1 3M Section 1 12/18/09 All container storage areas are located a minimum of 700 feet from the nearest property line. Special procedures have been established to minimize the hazards associated with the handling of poisons, oxidizers, compressed gases, carcinogens, biological wastes and substances that may react violently or explosively with water or that may be capable of polymerizing violently. These wastes are stored either in designated trailers based on compatibility, segregated in DOT categories in Building 60 or on containment pallets. The floor plan of the container staging area, Appendix I, shows an example of how the segregated areas of Building 60 can be used to separate and segregate the various classes of waste that may be stored. At times these areas may be used for other classes of waste than shown on the figure. Proper segregation of waste classifications will be maintained. 1.4 PROPER MATERIALS HANDLING Site operations are organized to minimize the amount of drum and container movement required at the incinerator. All employees working at the incinerator are trained to address the potential hazards associated with the contents of drums or containers. Proper packaging greatly minimizes the possibility of ignition of the waste in a container. To minimize the possibility of ignition of material outside a container, all material handling areas are well ventilated. Spark resistant tools (brass hammers, wrenches, etc.) are used on all containers and tanks storing ignitable materials. Grounding equipment is provided and used for the transfer of ignitable wastes. Drums on pallets are handled using forklifts. Before moving pallets of drums, the forklift operator observes the position of the drums to assure that they can be safely moved. Drum handling equipment also includes various drum handlers that attach to forklift tines and can move one or two drums at a time. Areas where ignitable waste containers are typically opened for processing are restricted as Class I, Division I, Group D areas. All equipment used in these areas during normal operations must meet or exceed the Class I, Division I, Group D rating. The forklifts used are rated appropriately for the areas where they are used.. Forklift training is provided to all operators. Forklift operators are required to obtain experience in safe forklift operating procedures before being allowed to drive a unit in a Class I Division I area. 1 -2 3M Section 1 12/18/09 Material handling and other equipment is positioned to minimize sources of ignition. Equipment that could produce sparks is not allowed into areas where combustible vapors could accumulate. If spark producing equipment must be brought into such an area, the concentration of combustible vapors in the atmosphere is first determined and continuously monitored with a portable organic vapor monitor. Only after a safe condition has been verified is spark producing equipment allowed in such an area. This activity requires a 3M spark permit. Shoe conductivity meters are located at the employee entrances to the incinerator. All persons who enter the production area must check for shoe conductivity on the meter. Persons whose shoes do not register adequately on the meter must wear static elimination grounding straps. 3M provides training regarding the site smoking policy to all employees. Smoking is allowed only in designated areas of the site. The policy is strictly enforced. When a waste is determined to be reactive or polymerizable, it can be introduced into the incinerator by one of the following methods: Wastes can be transferred directly into the kiln through the direct burn line without mixing with other materials prior to incineration. 2. If the waste is non pumpable or if it is undesirable to open the drum, the waste can be left in the drum and placed on the drum conveyors for delivery into the kiln feed chute through the drum feeder. 1.5 WASTE COMPATIBILITY Compatibility testing is conducted as outlined in Section C. Oxidizer and other non - compatible solid wastes are not fed to the Komar processor. Incinerator handling codes attached to the waste stream profiles of such wastes flag individual containers to prevent improper handling. 1 -3 3M Section J 12/18/09 SECTION J TRAFFIC CONTROL The 3M Cottage Grove Center is accessed via Innovation Road (County Highway 19), or Miller Road. Both are two -lane paved public roads. These roads provide adequate access for all incoming and outgoing vehicles. The distance to the nearest major highway, US Highway 61, from the main gate is one mile. Immediately prior to entering the facility, Innovation Road crosses a pair of railroad tracks. This grade crossing is controlled by automatic flashing lights and barrier arms. Traffic at the site moves primarily between the security entrance gate at Innovation Road and the main parking lot north of Building 116. Vehicular traffic in the plant proper (beyond Building 116) is restricted. (See Section D.2.3.) The speed limit for all vehicles within the plant site is 10 mph. Since Innovation Road south of Highway 61 terminates at 3M Cottage Grove Center, there is no through traffic. Traffic, essentially employees' vehicles, peaks during shift changes. An average of 750 3M employees work at the facility. Traffic to the incineration facility turns west (right turn) shortly after entering the site. A parking lot southeast of Building 145 is provided for incinerator personnel and visitors. A stop sign at the intersection of the incinerator access road and Innovation Road provides control of traffic exiting the site from the incineration facility. An average of 8 to 10 truck loads of waste per day are transported to the incinerator. The majority of waste is delivered in 48 -foot or 53 -foot tractor trailer trucks. Tanker trucks (generally 5,000 to 6,000 gallon capacity) deliver liquid waste. Bulk waste is delivered or shipped out in roll -off boxes or intermodal containers. Truck traffic to the incineration facility is a small fraction of the daily truck traffic to the other facilities at the 3M Cottage Grove site. Waste shipments from off -site enter the facility at the security entrance gate. The guards directs the truck to turn right and proceed to the incineration facility, where they must pass through a second barrier gate. Truck drivers sign in at the Shipping and Receiving office, are instructed where to park their trailer. Trucks leave the plant by turning left on Innovation Road and exiting at the security gate. All waste shipments to the incineration facility from on -site travel north through the security barrier at Building 116, turning west (left turn) at the incinerator access road. All roads in the plant area carrying routine traffic, including shipments of waste to and from the incinerator, are constructed of asphalt concrete paving and have a load bearing capacity of 9 tons axle weight. J -1 3M Section K 12/18/09 SECTION K OUTLINES FOR INTRODUCTORY AND CONTINUING PERSONNEL TRAINING The information contained in this section outlines the personnel training program for the 3M Cottage Grove Corporate Incinerator. This training program is conducted in accordance with the requirements of 40 CFR 264.16 (M.R. 7045.0454); 40 CFR 270.14(b)(12) (M.R. 7001.0560); and 29 CFR 1910.120(p)(7). In addition to the regulatory requirements, 3M provides additional training which is also outlined in this section. The training program has been designed to prepare personnel to operate and maintain the hazardous waste management units in a safe manner to ensure the protection of human health and the environment. The objectives of the training program are: • To enhance workers' awareness of the potential hazards at the facility • To provide the knowledge and skill necessary to perform their specific job tasks with minimal safety and health risks • To enhance workers' awareness of the purpose, need, and limitations of safety equipment • To ensure that workers can effectively respond to emergencies • To comply with EPA, DOT and OSHA training requirements. The regulatory training requirements applicable to this facility are listed in Table K -1. K -1 3M Section K 12/18/09 TABLE K -1 INCINERATOR AND RSCS TRAINING PROGRAM: REQUIRED TRAINING Course Name Requirement of Initial Annual Personnel Notes 1910.120 Regulation /Program C, Y All except Administration Monitoring and reporting Trained 1910.120 (b) HEALTH AND SAFETY Right to Know MN 5206.0700 C, Y Y All employees working Requirements of HAZCOM Hazard Communication 1910.1200 1910.134 y with hazardous waste or Operations with hazardous chemicals MSDS Information 3M Hazard infectious substances; Location & use of MSDS info Program. Communication maintenance personnel Methods to detect presence of hazardous Y Program Operations assigned to incinerator chemicals 1910.120 (h) Program. (incinerator maintenance) Methods to protect employees SCBA Fitness Test 1910.134 C, Y Y Labeling system, identifying hazchem MN182.653 (AWAIR) characteristics of classes of hazchem 3M Fleet Safety Y Y all employees who drive Handling of specific chemicals Safety Procedures 1910.120 C, Y O, y All Heat stress Y - Training required, length of training varies as needed for effectiveness Electrical safe Satety ana Fire Keguiations 1y1U.izu Y O,Y All Industrial Hygiene 1910.120 Y C, Y All except Administration Monitoring and reporting Chemistry Fundamentals 1910.120 (b) C Y O, Y All except Administration Chemical Safety Training 1910.120 (b) y O, Y All except Administration Respirator Training 1910.134 y y All except Administration; 3M Respirator incinerator maintenance Program. Care and Use of SCBA 1910.134 Y O, Y Operations Inc Respirator Program. SCBA Fitness Test 1910.134 C, Y Y operations 3M Respirator Prog. Fleet Safety 3M Fleet Safety Y Y all employees who drive Program the truck C - Continuing training after initial session, often supervised, on- the -job training - Optional Y - Training required, length of training varies as needed for effectiveness K -2 3M Section K 12/18/09 TABLE K -1 INCINERATOR AND RSCS TRAINING PROGRAM: REQUIRED TRAINING (continued) Course Name Requirement of Initial Annual Personnel Notes Regulation / Progra Trained m 24 Hour Safety and Health 3M Global Safety and Y Y All Health Plan AWAIR MN182.653 Y As All Actual content duplicates OSHA training needed need to explain program /goals Blood Borne Pathogens & MN5206.0700 Y Y All with exposure Regulation includes details for program Infectious Waste 1910.1030 and 1910.120 (b) record keeping Asbestos 1910.10010) Y Y Awareness for all; Health effects of asbestos Incinerator maintenance Locations in building personnel Recognition of damage /deterioration Housekeeping requirements Proper response to fiber release Confined Space Entry 1910.146 Y Y All who enter and rescue Manual 80 specifies classroom training Man 80, v2, A -120 team annually and entry drill every 3 years; rescue team: Annual entry drill Lockout/Tagout 1910.157 Y O, Y Operations; Policy Man 80, v2 A -112 Incinerator maintenance Procedures Retrain on deviation (1910.157) Hearing Protection 1910.95 Y Y All exposed to noise > 8 3M PPE Program hr weighted average of 85 decibels. Personal Protective 1910.132 Y Y All required to use PPE Also part of all levels of HAZWOPER Equipment 3M PPE Program training Process Safety Management 1910.119 (g) Y Y All except Administration; Program requirements Inc. PSM Program Incinerator maintenance Mechanical Integrity 1910.1190) Y Incinerator maintenance C - Continuing training after initial session, often supervised, on- the -job training O - Optional Y - Training required, length of training varies as needed for effectiveness K -3 3M Section K 12/18/09 TABLE K -1 INCINERATOR AND RSCS TRAINING PROGRAM: REQUIRED TRAINING (continued) Course Name Requirement of Initial Annual Personnel Notes Regulation / Progra Trained m Management of Change 1910.119 (1) Y All Ergonomics 3M Ergonomics Y O, Y All Injuries and illnesses (Cumulative Trauma ) Safe work methods Program Job hazards Medical management/reporting Job specific hazard recognition Back safety EMERGENCY RESPONSE General Emergencies/ 1910.120 (p) Y Y All Emergency shutdown procedures Contingency Plan Notification procedures Spill Control, Containment 1910.120 (p) C, Y Y All except Administration Containment, notification, clean -up and Decontamination decontamination procedures Emergency Response/ 1910.38 (a) (b) C, Y Y All Evacuation procedures, Evacuation Procedures Alarm locations FIRES /EXPLOSIONS Fires Control and Prevention Y O Y All oxidizer materials Fire Training Exercise O, Y Fire Extinguishers 1910.157 Y Y All employees designated Annual refresher may be class or Man80, v2,A -102 to use fire extinguishers distributed instructions C - Continuing training after initial session, often supervised, on- the -job training O - Optional Y - Training required, length of training varies as needed for effectiveness K -4 3M Section K 12/18/09 TABLE K -1 INCINERATOR AND RSCS TRAINING PROGRAM: REQUIRED TRAINING (continued) Course Name Requirement of Initial Annual Personnel Notes Regulation /Progra Trained m PLANT OPERATIONS Fork Lift Training and 1910.178 Certification Manual 80,v2,A -118 Introduction to Plant Operations Standard Operating Procedures Computer Bar Coding ENVIRONMENTAL Regulated Materials Training 172.700 (DOT /RCRA) Storm Water Pollution Site Storm Water Prevention Pollution Prevention Plan 40CFR 122.26 Y Y Operations (evaluate every 3 yrs or on def.) Y O, Y All Y 0, Y All Y 0, Y Operations C, Y Y (every All with exposure to 3 years) hazardous materials (general awareness and function specific) Y Y (every All except Administration 2 years) 1910.178 lists elements of training Man 80 stipulates annual hearing /vision test for certified operators and hands on refresher training at least every 3 years or as needed Position specific, may include confined space entry, lockout/tagout and other operating policies(see specific requirements) Position specific Loading /unloading procedures Packaging /marking /labeling; Waste segregation in loads /storage; Placarding; Shipping papers Train so that employees who handle hazardous substances and waste products (sludge /ash /slag) that have potential to be released with storm water discharges are aware of their responsibilities C - Continuing training after initial session, often supervised, on- the -job training O - Optional Y - Training required, length of training varies as needed for effectiveness K -5 3M Section K 12/18/09 K.1 JOB TITLES AND DUTIES For each incinerator position, the job title, and detailed written job descriptions of duties is maintained at the facility. Maintenance personnel (i.e. electricians, millwrights, mechanics, etc.) may also work in waste handling areas but do not handle wastes directly. Training is provided to employees commensurate with their job duties and responsibilities Training requirements are assigned by groups as outlined in the table below. The training group name is in the left column with job titles listed on the right. TABLE K -2 JOB TITLE AND DUTIES Mfg Production Sup S &R/WWT Sup. a Temp General Supervisor Temp Mfg Production Sup Technical Manager Analytical Chemist Environmental Engineering/ Regulatory Compliance Green Belt Coach U) Lab Technician `o Operations Manager ° PI &CS Engineer U. Planner Process Engineer Project Engineer Safety/ Health Specialist o POI N c PO2 L PO2 Trainee C S &R Operators a Int'I Waste Mgmt. Coordinator Tanker unloadin Mfg Production Sup S &R/WWT Sup. a Temp General Supervisor Temp Mfg Production Sup Technical Manager Analytical Chemist Environmental Engineering/ Regulatory Compliance Green Belt Coach U) Lab Technician `o Operations Manager ° PI &CS Engineer U. Planner Process Engineer Project Engineer Safety/ Health Specialist o Admin. Coordinator RSCS Admin. Res. Recovery N Adv. RR Specialist C E Analyst Mfg. Operations a Int'I Waste Mgmt. Coordinator K -6 3M Section K 12/18/09 Office Administrator Resource Recovery & Contract Disposal Manager Software Engineer US External Vendors Coordinator WSP Coordinator S Fitter d Systems a Mechanic w I Electrician K.2 EMPLOYEE TRAINING Incinerator staff receive hazardous waste training in several ways, including classroom, computer based training, and on-the-job training. New employees receive initial training. All employees also receive specific training related to their job duties. In addition, 3M provides special training programs annually to all Incinerator employees. The training program at the Incinerator includes: • Assignment of roles and responsibilities for training program components. • Developing and maintaining a matrix matching employees with required compliance and skills training for their job duties including initial training and frequency of refresher training. • Providing the required training to all new employees and all reassigned employees appropriate to the new job duties. This includes information on general safety and health rules for the location. • Training for all employees involved in potentially hazardous operations, or in jobs that require handling or exposure to hazardous materials. Training is done initially and periodically as needed or required by regulations or policies. Some examples of this training include the following: - Proper work procedures. - Safe handling requirements of hazardous elements. - Assessment of ergonomic hazards. - Material safety data sheets. - Labeling and container requirements. - Personal protection. - Emergency response procedures. K -7 3M Section K 12/18/09 • Training engineers and supervisory employees, including managers and team leaders, on appropriate loss prevention, safety, and industrial hygiene appropriate to new duties. • Ensuring contract and temporary workers receive the same training as regular employees appropriate for the job. • Ensuring training content includes all current regulatory requirements for that topic and hands -on practice, where applicable. Providing trainers who have appropriate qualifications for the subject matter they are presenting and for training techniques whether they are internal or external trainers. K.2.1 Initial Training Program All employees in positions related to hazardous waste management complete a minimum of 24 hours of initial training,8 hours of orientation training and 16 hours of job-related training, before beginning extensive on- the -job training under the direction of the new employee's supervisor. Table K -3 summarizes the content of orientation and initial job - related training received by a new employee according to position. Representatives of management at the incinerator and members of the operations and technical staffs conduct the orientation training program. This program lasts a minimum of eight (8) hours and includes a discussion of the following topics: • General site safety and emergency procedures. • The capabilities of the facility and restrictions imposed upon the facility. • The types of wastes managed and the processes and equipment used for waste treatment and storage. • The regulatory requirements that apply to the facility. • The importance of maintaining compliance. • OSHA - related safety items. K -8 3M Section K 12/18/09 Plant Operations 1 2 L L 2 2 2 u..:..HO :....7.,.. (t,.,.) 1 2 2 2 Standard OpeFating Procedures (hFs Waste Labeling —El DOT Tfaip�ag (hrs) 4 4 4 a 2-8-R 4-e -Eat 2 K -9 4 4 3M Section K 12116/09 K -10 3M Section K 12/18/09 TABLE K -3 Initial Training by Position Course Category /Title c c 0 cu O c m o E m (D 0) � L o •+-� m N E Q rn c ^ C W Health and Safety Right to Know /Hazard Communication /MSDS Safety Procedures Safety and Fire Regulations Industrial Hygiene Asbestos Awareness Personal Protective Equipment Blood Borne Pathogens/ Infectious Waste Process Safety Management Chemistry Fundamentals Chemical Safety Training Ergonomics /Back Safety Respirator Training Care /Use of Self Contained Breathing Apparatus Self Contained Breathing Apparatus Fitness Test y y Y y y Y y y Y y y Y y y Y y y Y y y Y Y y Y y y Y y y Y o) Emergency Response General Emergencies /Contingency Plan Spill Control and Containment Emergency Response /Evacuation Procedures y y Y y y Y y y Y Fires /Explosions Fires and Explosions Y y I Y Plant Operations Fork Lift Training and Certification Hoist/Rigging Introduction to Plant Operations Standard Operating Procedures Computer Bar Coding Waste Labeling and DOT Training o y Y y y Y v y (a) a (a) y a (o) = optional, position dependant (a) = awareness K -11 3M Section K 12/18/09 Special emphasis is given to the following topics during this initial training: • Basic review of the chemical and physical hazards of the materials, equipment, and wastes handled within the facility, including safety precautions minimizing risk of personal injury while performing job duties. • Policies and procedures regarding monitoring equipment and controls. • Contingency plans and emergency procedures including: a) safety equipment location and use b) fire fighting equipment location and use c) spill control procedures and equipment d) system waste feed cut -off procedures and controls e) emergency process shutdown procedures f) emergency alarms g) evacuation routes h) proper notification procedures i) other emergency response procedures. Following the successful completion of the orientation training program, each new employee receives at least sixteen (16) hours of training that relates specifically to his or her new duties. This training program is conducted by members of the operations and technical staff as well as the new employee's supervisor and other supervisory personnel. Included is a comprehensive review of the facility covering emergency equipment, emergency showers and eye wash stations, emergency shut -off controls, fire prevention and control equipment, alarm and communication systems, and primary and alternate evacuation routes. K.2.2 Job - Related Training Program The job - related training program includes reinforcement of discussions on topics discussed in the initial training program. Areas not related specifically to the new employee's normal duties are also reviewed. The relationship of the employee's job to the jobs of other personnel in the area is emphasized. K.2.3 Annual Training Programs A series of ongoing training programs, which cover various emergency response and safety policies and procedures, is conducted for all employees on an annual basis. Table K -4 lists K -12 3M Section K 12/18/09 annual training courses required at the incinerator by position. Most annual training is conducted during the yearly shutdown of incineration operations. Additional training is scheduled as needed throughout the year. Emphasis at these sessions is placed on the safe operation of all equipment and the safe handling of all materials. Training provided to each employee is commensurate with job responsibilities and work areas. The special training program also emphasizes emergency response to fires, spills, and other unusual occurrences that could threaten the environment, the health and safety of employees, or residents of surrounding communities. Training includes the location and proper use of all equipment employed in an emergency response, notification procedures, and the policies and procedures for working with local, state, and federal response groups. TABLE K -4 Annual /On -going Training by Position Course Category /Title N c O c6 N Q O N c c (D OE c0 N a) (B Q � 2 O O FL o ,� CO N c ¢ c N d c W Health and Safety Right to Know /Hazard Communication /MSDS o 0 0 0 0 Safety Procedures o 0 0 0 0 Safety and Fire Regulations Industrial Hygiene Asbestos Awareness Personal Protective Equipment Blood Borne Pathogens/ Infectious Waste Process Safety Management Chemistry Fundamentals Chemical Safety Training y (0) 0 0 0) o Ergonomics /Back Safety o Respirator Training Care /Use of Self Contained Breathing Apparatus Self Contained Breathing Apparatus Fitness Test Emergency Response General Emergencies /Contingency Plan o 0 Spill Control and Containment K -13 3M Section K 12/18/09 Emergency Response /Evacuation Procedures Fires /Explosions Fires and Explosions o 0 Plant Operations Fork Lift Training and Certification Hoist/Rigging Introduction to Plant Operations Standard Operating Procedures Computer Bar Coding Waste Labeling and DOT Training, 3 y (3)(o o 0 0 0 0 y (3) (o) = optional, position dependant (a) = awareness (3) = every 3 years K.3 JOB - SPECIFIC TRAINING training program is structured to provide job- specific training to personnel. For example, the incinerator operations supervisors receive training in record keeping and other procedures required for compliance and the operators do not. Operators are more specifically trained to maintain proper and safe operating conditions and to respond effectively in the event of a spill or other emergency. K -14 3M Section K 12/18/09 IJIMM 3M Section K 12/18/09 K.4 TRAINING FOR EMERGENCY RESPONSE The 3M Cottage Grove Incinerator training program is designed to ensure that personnel not only handle hazardous wastes in a safe manner but also properly respond to emergency situations. Training elements addressing non - routine and emergency situations (unscheduled shutdowns and startups related to storms, power outages, fires, explosions, spills, etc.) include: • Procedures for locating, using, inspecting, repairing, and replacing facility emergency and monitoring equipment, • Key procedures for automatic waste feed cutoff systems. • Emergency communication procedures and alarm systems. • Response to fires or explosions. • Procedures for containing, controlling, and mitigating spills. • Procedures for shutdown of operations and power failure. • Procedures for evacuation. In addition to the incinerator's hazardous waste management personnel, 3M Cottage Grove Center maintains an emergency squad for response to fires and other plant emergencies. The emergency squad receives classroom and field fire - fighting training, as well as instruction in first aid and cardiopulmonary resuscitation (CPR). K.5 IMPLEMENTATION OF TRAINING PROGRAM All current personnel involved with the management and handling of hazardous waste have been fully trained at the time of this submittal. All new personnel who will be involved in the hazardous waste management program will complete this training program within six months of assignment to the Corporate Incinerator. New employees are not permitted to work in unsupervised positions until they have completed the required personnel training. K.6 RECORDKEEPING The Cottage Grove Corporate Incinerator maintains records regarding the hazardous waste training program on all current and former employees according to the requirements of 40 CFR 264.16 (M.R. 7045.0454 Subpart 7). The facility has developed a matrix in Microsoft Excel for training records that includes the names and employee numbers of each employee, the title of each training session, length of each session, and identifies the sessions missed. Sign -in forms for each training session include session name, date and K -16 3M Section K 12/18/09 time of session, length of session, trainer name, description of the training session, and the names and employee numbers of the attendees. K.7 OTHER TRAINING PROGRAMS The Cottage Grove Corporate Incinerator provides additional training beyond that required by the hazardous waste rules. Training is also provided to employees in fulfillment of rules administered by the Occupational Safety and Health Administration (OSHA) and the Department of Transportation (DOT), and to comply with 3M internal programs and policies. A listing of training areas typically covered is as follows: • Environmental Management System (EMS) • Employee Access to Medical Records • Hazard Communication Program • Hazardous Waste Operations and Emergency Response (HAZWOPER) • DOT Requirements for Waste Shipments • Spill Prevention, Control and Countermeasure (SPCC) Plan • Personal Protective Equipment • SARA Title I II • Forklift Operations • Fire Extinguishers • Respirator Fit Testing /Physical Requirements • Hearing Conservation /Noise Standards • Job Safety Analysis • Industrial Hygiene • Blood Borne Pathogens /Infectious Waste • Asbestos • Electrical Safety Related Work Practices • Confined Space Entry Procedures • Lockout/Tagout Procedures • Line Breaking Procedures • Injury and Illness Reporting • Contractor Representative • Contractor Interfacing for Supervisors • Process Safety Management • Department of Transportation (DOT) General Awareness (HM -126) • Toxic Substance Control Act (TSCA) K -17 3M Section K 12/18/09 Minnesota AWAIR Program K -18 3M Section L 12/18/09 SECTION L CLOSURE PLAN LA CLOSURE PLAN This section is submitted in accordance with the requirements under MR 7045.0486, .0488, .0498, .0502, .0504, and .0518. This plan identifies steps necessary to close the 3M Cottage Grove Corporate Incineration facility partially or completely at any point during its intended operating life. A post - closure plan is not required because the facility is not a disposal facility and all hazardous wastes stored for treatment will be removed at closure. Copies of the closure plan and any revisions to the closure plan will be maintained at the 3M Corporate Incinerator at Cottage Grove until the certification of closure completeness has been submitted and accepted by the MPCA. The MPCA will be notified at least 45 days prior to the commencement of final closure. The final closure date of this facility has not been determined but is not foreseen to be in the immediate future. Upon completion of closure, a statement of certification, signed by a qualified independent registered professional engineer, will be submitted to the MPCA. This certification will verify that the facility has been closed in accordance with the specifications in the approved closure plan. Steps and procedures necessary for the treatment and /or removal of all hazardous wastes and decontamination of structures and equipment and are presented in this closure plan for all hazardous waste management units at the facility. The closure plan has been designed to: (1) ensure that each closed hazardous waste management unit will not require future maintenance or post - closure activities and (2) prevent the release of hazardous waste to the environment during closure. 3M Corporate Incineration facility personnel will respond to any release of hazardous waste in accordance with guidelines stated in Section G, Contingency Plan. Appropriate health and safety practices will be followed during all phases of closure to protect personnel from exposure to hazardous waste. The closure plan will be amended if any changes occur in the applicable regulations, operating plans, or treatment equipment that affects the closure plan (such as unit size or capacity, maximum closure inventory, or closure schedule or costs). The plan will also be amended, as required, if there are any technical changes such as application of a new technology, changes in monitoring requirements, or new operating plans or contingencies. L -1 3M Section L 12/18/09 The maximum inventory of all hazardous wastes in storage will be: (1) Trailer Storage Areas 1,993,600 gallons (2) Docks and Buildings 188,600 gallons Buildings 47, 60, 77, 136, 145 (3) Storage Tanks, including wastewater sludge 406,300 gallons (4) Laboratory Operations 100 gallons The source of these figures is provided in Section LA, Maximum Waste Inventory. L.2 CLOSURE PERFORMANCE STANDARD The 3M Cottage Grove hazardous waste management unit closure plan has been developed to eliminate the need for any post closure maintenance. It has been designed to protect and prevent threats to human health and to minimize or eliminate the release of hazardous wastes, hazardous waste constituents, waste decomposition products, or contaminated runoff to the ground, groundwater, surface water, or atmosphere. All hazardous wastes and hazardous waste residues will be removed from the facility. If there is evidence of contaminated soil, an evaluation will be made as to whether the soil can be decontaminated or excavated and disposed of at a permitted disposal facility. Proper disposal and handling practices will be used for all contaminated materials. L.3 PARTIAL AND FINAL CLOSURE ACTIVITIES L.3.1 Partial Closure Activities In the event that future circumstances lead to discontinuing or modifying a particular area or process component for the purpose of partial closure, the closure plan will be amended accordingly. Implementation of any partial closure plan will not adversely affect the ability of the facility to meet permit of regulatory requirements. L.3.2 Final Closure Activities Past Closure Activities • The boiler ash landfill area formerly used as a processing surface for incinerator ash and sludge was closed in 1984. All incinerator ash and sludge on the surface of the landfill was removed and properly disposed of either by shipping to a permitted landfill or recycling. The landfill has a High Density Polyethylene and soil cover that is maintained to avoid infiltration of precipitation through the landfill. L -2 3M Section L 12/18/09 • Under a letter to MPCA dated December 21, 1994, 3M provided a report summarizing the Ash House Waste Pile closure activities and information relating to the status change of the Bulk Solids Storage Building to Containment Building. All waste was removed from the units and transferred into roll -off boxes for off -site shipments. All concrete surfaces were cleaned with high pressure water sprays. The dry floors and trenches were inspected. There was no evidence of any crack or gap that would have allowed waste to migrate from the unit. Both units continued to operate: the Ash House as a process area and the Bulk Solids Storage Area as a Containment Building until the fall of 1997 when a new Containment Building (Building 181) was opened and the old Containment Building (formerly known as the Oakdale Building) underwent closure. • Closure of old kiln - In 2002 and 2003, partial RCRA closure activities were conducted for the original kiln and associated equipment. Specifically, the units that were closed included: • Waste Heat Boiler Building (Building 33) • Ash Metal Separation Building • Stack Area: stack, CEM Building, auxiliary building • Precipitator (Building 61) • APC Equipment: fiberglass duct work, hot duct, bypass quench, catenary grid scrubber, packed tower, cross flow scrubber, ID fan • Ash House • Kiln and Appurtenances: rotary kiln, kiln discharge area, mix chamber, SCC and emergency stack • Portions of Building 47, including the Pak Feed Room and the Kiln Head Room • Chemical Sewer All activities were conducted in accordance with a work plan reviewed and approved by MPCA. These activities included dismantling and demolition, decontamination, and disposal. Additionally, a site assessment was conducted, and impacted soils were removed. On November 7, 2003, 3M submitted a report to the agency describing all activities related to this partial closure. On February 24, 2004, MPCA formally approved the closure. • Closure of Waste Storage Tanks L -3 3M Section L 12/18/09 In 2004 3M installed a new tank farm system. In April of 2005 3M submitted to the MPCA a work plan for partial closure of the old waste tank farm. The plan called for the decontamination and removal of eleven tanks and the associated pumps, piping, etc. This plan was approved by the MPCA on June 10, 2005. 3M then proceeded to remove the tanks and equipment. Anticipated Partial Closure Activities There are no anticipated partial closure activities at the time of this submittal. Planned Final Closure Activities Each hazardous waste management unit will be closed in accordance with the following assumptions: 1. All closure activities will be structured so that clean -up residues and equipment wash water can be collected and treated in a manner consistent with regulatory disposal requirements and the wastes' hazardous characteristics. 2. An approved permitted facility can receive the material requiring off -site disposal. 3. A widespread release of contaminated material has not occurred. 4. All hazardous and non - hazardous wastes will be transported to an approved off -site facility once the existing incineration equipment has been shutdown. Prior to any closure activities, a closure work plan describing in greater detail the specific closure activities for each individual area will be submitted. If, during closure, contamination of hazardous waste or constituents is discovered beyond the scope of the closure plan, a revised closure work plan, further detailing decontamination or removal procedures, equipment, remedial technologies, and clean -up levels, will be submitted to the MPCA for approval. L.4 MAXIMUM WASTE INVENTORY A summary of the maximum waste inventory was provided in Section L1. Further discussion of each of the numbers listed is provided below: 1) Trailer Storage Areas - A detailed listing of trailer storage areas is provided in Section S1.3 Container Storage Areas, Trailer Storage Lots 2) Docks and Buildings - A detailed listing of container storage areas is provided in Section S1.3 Container Storage Areas, Buildings 47. 60 and 145 and Other Buildings and Docks L -4 3M Section L 12/18/09 3) Storage Tanks - A detailed listing of storage tank capacities is provided in Section S2.1. The total current storage capacity of 361,130 gallons includes eight waste storage tanks at 18,360 gallons each (Tanks 21 -28), Tank No. 1 (200,000 gallons), one 10,000 gallon decant tank Tank 20, and two process sludge tanks at 2,150 gallons each. 4) Laboratory - It is estimated that the laboratory can contain up to 100 gallons of laboratory waste, reagent grade chemicals, laboratory samples, and waste chemical products. L.5 INVENTORY REMOVAL, DISPOSAL, AND DECONTAMINATION OF EQUIPMENT L.5.1 Inventory Removal and Disposal Prior to beginning closure activities, the waste inventory will be reduced to the greatest extent possible. All wastes remaining will be disposed of at an approved off -site facility. Complete manifest records will be kept as to the date of shipment, waste characterization, waste quantity, the disposal facility used and other appropriate information. Waste transportation to off -site facilities will be performed in accordance with DOT regulations. At the time of closure, trailers used to store containers (i.e., 55- gallon drums) will be inspected by 3M after removal of all containers and before the trailers leave the facility. Wastes generated from closure operations will be placed in appropriate containers or trucks for shipment to approved off -site facilities. L.5.2 Decontamination of Equipment Major equipment to be decontaminated is identified in Section L.5.3 for the container storage areas, in Section L.5.4 for the tank farm areas, and Section L.5.5. for the incinerator. Those sections also describe the decontamination procedures. Secondary containment areas will be utilized when possible for decontamination activities. Major process equipment will be decontaminated in place. Temporary containment berms will be installed as necessary to contain the decontamination materials. The equipment will be internally and externally flushed with water, detergent, and /or solvents depending upon the nature of the waste handled in the past. Equipment will be decommissioned and decontaminated on -site in an appropriate manner. Any spill occurring during equipment decommissioning will be contained and cleaned up, and the area will be decontaminated. L -5 3M Section L 12/18/09 An appropriate site assessment and soil sampling plan will be submitted to the agency prior to closure. If contamination is determined to be present, appropriate remediation activities will be conducted in accordance with MPCA guidelines. Personnel involved in decontamination and decommissioning activities will wear protective clothing and equipment to prevent exposure to the hazardous waste constituents and to minimize human health hazards. The personnel protective equipment and decontamination equipment will be evaluated to determine appropriate disposal and /or decontamination procedures.. L.6.3 Closure of Container Storage Areas Following removal of waste inventory for off -site disposal, trailer containment liners will be cleaned with high pressure steam. Steam cleaning will be conducted in an area designed to contain condensate. After steam cleaning, a visual inspection will be conducted. Cleaning will be repeated as necessary. Following the removal of all trailers, the designated trailer storage lots will be inspected. Sampling will be conducted in accordance with a sampling plan to be submitted to the agency prior to closure. If contamination is determined to be present, appropriate remediation activities will be conducted in accordance with MPCA guidelines. Enclosed container handling and storage areas (concrete surfaces with chemically resistant coatings that are present in docks and buildings) will be cleaned with high pressure stream. Any rinse water or cleaning residue will be treated in accordance with the hazard characteristics as determined by analysis or regulatory requirements. A visual inspection of the concrete floor in the container storage areas for cracks and other signs of migration of hazardous waste constituents will be made to verify that no migration into the concrete has taken place. No migration of contaminants into the concrete is expected since the containers are stored on pallets, the floors are sealed with a chemically resistant coating, and action is taken immediately to clean up any observed spills. Workers will wear the appropriate personal protective equipment (PPE) for all closure activities. L.6.4 Closure of Tanks All hazardous wastes will be removed from each tank, and all associated process lines will be drained in preparation for decontamination. Tanks will be decontaminated by triple rinsing with an appropriate rinse material, followed by visual inspection. After the tank decontamination process is completed, the tank secondary containment system will be cleaned with high pressure steam. All liquid and solid residues will be managed in accordance with the waste L -6 3M Section L 12/18/09 characteristics and other regulatory requirements. Workers will wear appropriate personal protective equipment for all closure activities. All piping to and from the storage tanks will be rinsed with an appropriate rinse material. The piping will then be disconnected and dismantled. Spill containment will be used in the event of a spill resulting from pipe drainage during the dismantling process.. Personnel performing the dismantling and decontamination will be equipped with appropriate safety clothing and equipment. Extreme caution will be taken during all decontamination and cleanup activities. Non - sparking tools and equipment will be used as required. All dismantled piping will be sent to 3M approved TSDF or recycling facilities. . L.5.5 Closure of the Incinerator After the Incinerator system has been shutdown for decommissioning, material and residue from the feed systems, the ash handling system, and the APC devices will be containerized and transported to a permitted, off -site TSDF or, if appropriate, decontaminated. The incinerator system (rotary kiln, secondary combustion chamber, gas cooling system, gas cleaning system, and ash removal system) and its associated systems and equipment (feed system, feed preparation equipment, and scrubber water collection and pretreatment equipment) will be decommissioned. All surfaces that have contacted waste, ash, flue gases or scrubber water will be washed and triple- rinsed with water (and detergent, as required) or sandblasted as appropriate. Wash and rinse solutions will be transferred to tank trucks and transported to an approved, off -site TSDF. Representative samples of the rinsate will be appropriately tested. Decontamination procedures will be repeated (wash and rinse) until the samples collected reach decontamination specifications. High - pressure steam may also be used for decontamination. Specific decontamination procedures will be listed in the closure work plan. Workers will wear appropriate PPE during all closure activities. The wastewater treatment plant facilities (the mix tanks, the three settling tanks, and the sludge thickener) will be washed and rinsed to remove solids and then turned over to the wastewater treatment plant to be used to treat other plant wastewater. The Ash House and the Bulk Solids Containment Building (Bldg 181) will be closed as part of incinerator closure. All waste stored in these areas will be transported to a permitted, off -site TSDF. All surfaces in these buildings will be cleaned to remove any residual contamination. Steam cleaning should be sufficient for most equipment building surfaces and concrete floors. Condensate will be collected and tested to ensure that all surfaces are adequately cleaned. L -7 3M Section L 12/18/09 Concrete surfaces that are eroded will be sand or shot blasted. All solid residuals will be transported off -site to an approved landfill. All employees will wear appropriate PPE. Visibly contaminated or suspect areas outside the storage area may require soil investigation and removal. Specific decontamination procedures and investigative techniques will be described in the closure work plan. L.5.6 Closure of Waste Piles There are no hazardous waste piles at the 3M Cottage Grove facility L.5.7 Closure of Surface Impoundments There are no hazardous waste surface impoundments at the 3M Cottage Grove facility. L.5.8 Closure of Landfills There are no hazardous waste landfills at the 3M Cottage Grove facility. L.5.9 Closure of Land Treatment There are no hazardous waste land treatment units at the 3M Cottage Grove facility. L.6 SCHEDULE FOR CLOSURE The MPCA will be notified at least 45 days before implementing final closure procedures. All hazardous and non - hazardous wastes in the container storage areas and storage tanks at the commencement of closure activities will be removed off -site for disposal within 90 days after the receipt of the final volume of waste. All final closure activities will be completed within 180 days after the receipt of the final volume of waste or the facility will petition the MPCA for an extension under MN 7045.0488 Subpart 2. Closure operations will be supervised and certified by 3M personnel as well as by an independent professional engineer. L.7 EXTENSIONS FOR CLOSURE TIME Unforeseen circumstances may result in extending the closure schedule. Any extensions needed to complete the project will be subject to agency approval. L.8 POST- CLOSURE PLANS L -8 3M Section L 12/18/09 Post - closure care will not be needed for this facility because it is not a disposal facility and all hazardous wastes will be removed during the closure activity. L.9 NOTICE IN DEED AND NOTICE TO LOCAL LAND AUTHORITY Because the 3M Cottage Grove plant is permitted as a hazardous generator, storage, and treatment facility, notification is not necessary in the deed informing potential purchasers of restrictions associated with a disposal site. L -9 3M Section M 12/18/09 SECTION M CLOSURE COST ESTIMATE AND FINANCIAL ASSURANCE MA CLOSURE COST ESTIMATE The closure cost estimate for the facility is based on the disposal of the maximum permitted waste storage volume. The cost estimate is based on the assumption that maximum inventory will be present when closure activities begin. This is very conservative, in that efforts will be made to reduce inventory to the greatest extent possible prior to beginning closure activities. An updated estimate of the cost of closing the 3M Cottage Grove Center Incineration facility is submitted annually by April 1 to the MPCA. Closure costs include: 1. Treatment/disposal of on -site wastes 2. Decontamination of equipment and materials 3. Disposal of decontamination residues 4. Transportation of wastes to permitted, off -site facilities 5. Sampling and analytical work 6. Manpower 7. Regulatory assistance 8. Contingency and administration 9. Closure certification. No salvage credits are included in the closure cost estimate. The estimated cost is for decontamination of the site and not demolition /restoration. A copy of the 3M Cottage Grove Center closure plan and cost estimate will be kept on file at the facility. The closure cost estimate will be adjusted (1) annually for inflation within 60 days prior to the date the closure estimate was prepared and (2) when changes in the closure plan affect the cost of closure. M.2 FINANCIAL ASSURANCE MECHANISM FOR CLOSURE 3M meets the financial test and corporate guarantee for closure as discussed in Section M.2.1 and does not need not establish a financial trust to insure the required funds are available to cover the closure costs. M -1 3M Section M 12/18/09 M.2.1 Financial Test and Corporate Guarantee for Closure Letters regarding financial assurance for closure of the 3M Cottage Grove facility are supplied annually to the MPCA under separate cover. These letters certify that 3M meets the Financial Test and Corporate Guarantee for closure. M.3 POST - CLOSURE ESTIMATE Since all wastes will be disposed off -site, there will be no post - closure activities or costs. MA FINANCIAL ASSURANCE MECHANISM FOR POST - CLOSURE Since all wastes will be disposed off -site, there will be no post - closure activities or costs. M -2 3MSEC N- Rev.2.DOC 02/28/12 SECTION N CORRECTIVE ACTION This section addresses the requirements of M.R. Parts 7045.0484, 7045.0485, 7045.0512 and 7045.0514. No corrective action measures have been identified for any of the Solid Waste Management Units identified by the RCRA Facility Assessment (RFA) completed by MPCA in 1987. N.1 CORRECTIVE ACTION FOR SOLID WASTE AND HAZARDOUS WASTE MANAGEMENT UNITS Fifteen solid waste management units (SWMU) are identified in the RCRA Facility Assessment completed in June 1987 by MPCA. The status for each of the identified SWMUs is summarized in Table N -1. N.2 COST ESTIMATE FOR CORRECTIVE ACTION N.2.1 Cost for Monitoring at Solid Waste Management Units (SWMU) Currently, no corrective action is anticipated at any of the SWMUs identified by the 1987 RFA. Ground water monitoring will be managed in conjunction with the approved site -wide ground water monitoring plan under the 2007 Consent Agreement related to PFCs. Cost of the monitoring program is estimated at $1,000 per year. N.3 FINANCIAL ASSURANCE FOR CORRECTIVE ACTION Since no corrective action beyond monitoring has been identified, a financial assurance statement relative to corrective action is not required. N -1 3MSEC N- Rev.2.DOC 02/28/12 TABLE N -1. SUMMARY OF SUGGESTED FURTHER ACTIONS Unit Status 1. Coal Pile Runoff Pond 2. Waste Storage Runoff Pond 3. Cooling Water Ponds 4. Wastewater Treatment Polishing Ponds 5. Fire Training Area Runoff Pond 6. Concentrated Ammonium Sulfate Ponds 7. Iron Oxide Drying Bed 8. Site D1, HF Neutralization Pit MPCA notified of discontinuance of coal pile use with shutdown of site boiler and coal pile removal. In service and included in site stormwater permit In service and included in site NPDES permit. Basin 1 is in service, and included in the current NPDES permit. Basins 2 and 3 were removed in 2005 -2006 in accordance with the requirements of the current NPDES permit. Included in site NPDES permit. Pond out of active service. MPCA notified and ponds were removed. MPCA notified and drying bed was removed. Unit removed under the 2007 Consent Agreement with MPCA related to PFCs . Backfilled and covered in 2010. 9. Site D2, Sludge Disposal Area 10. Site D3, Boiler Ash Site 11. Site D4, Phenolic Waste Pit 12. Site D5, Solids Burn Pit Area Material removed under the 2007 Consent Agreement with MPCA related to PFCs. Backfilled and covered in 2010. Unit removed in 1980's under Consent Order with MPCA. This site has been excavated and covered. Unit removed in 1980's under Consent Order with MPCA. This site has been covered. Unit removed in 1980's under Consent Order with MPCA. N -2 3MSEC N- Rev.2.DOC 02/28/12 13 14 15 TABLE N -1. SUMMARY OF SUGGESTED FURTHER ACTIONS (continued) Unit Status Site D6, Former Ash Disposal Area Unit taken out of service and covered in place in 1980's under Consent Order with MPCA. Site D7, Pit Burning Area Unit removed in 1980's under Consent Order with MPCA. Site D8, Waste Disposal Area Material removed in 1980's under Consent Order with MPCA. This site has been covered. N -3 3M Section O 12/18/09 SECTION O LIABILITY COVERAGE 0.1 LIABILITY INSURANCE 0.1.1 Sudden Accidental Insurance The 3M Company is self- insured in case of bodily injury and property damage to third parties caused by sudden accidental occurrences arising from operation of this hazardous waste treatment facility. Appendix O contains a copy of the letter stating self- insurance sent to the EPA Region V Administrator. 0.1.2 Non - Sudden Insurance Requirements for non - sudden insurance apply.only to surface impoundments, landfills, or land treatment disposal facilities, none of which applies to the 3M Cottage Grove Center facility. 0.1.3 Variance and Adjustment Procedures It is not anticipated that the 3M Company will petition the EPA Region 5 Administrator or MPCA for a reduction in the liability amounts. If future legislation increases the amounts of liability coverage or imposes non - sudden liability coverage requirements to incinerators, 3M Company will adjust the insurance provisions discussed previously to comply with the revised requirements. 0.2 STATE ASSUMPTION OF RESPONSIBITY It is not anticipated that 3M Company will request state assumption of the legal or financial responsibilities. O -1 3M Section P 12/18/09 SECTION P TOPOGRAPHIC MAPS This section provides topographic maps showing the 3M Cottage Grove Center site. Figure P -1 shows the extent of the Cottage Grove facility at a scale of 1" = 200' Figure P -2 details the extent of the incinerator facility at a scale 1" = 80'. Each figure shows the location of the property line, fences and gates, buildings, drainage divides, drainage flow direction, drainage structures, storm sewer lines /culverts, fire water systems, chemical sewers, and intermediate streams. Buildings used in treatment and storage of hazardous waste are shown in Drawing No. CHEM- 888 -C -142 in Appendix A of this permit renewal application. The Cottage Grove Center site does not fall within the 100 -year flood plain. Subsequently, the 100 -year flood plain is not depicted on the facility drawings. Additional information is provided in Section Q. P -1 3M Section Q 12/18/09 SECTION Q FLOOD PLAIN INFORMATION The 3M Cottage Grove Center site does not fall within the 100 -year flood plain. The natural contour of the site precludes the occurrence of a 100 -year flood from impacting the site. This is based on a copy of the Federal insurance Administration flood map found in this section. The Cottage Grove Center facility falls in areas designated outside a 500 -year flood. Q -1 3M Section R 12/18/09 SECTION R APPLICATION FEE Based on the criteria outlined in M.R. 7046.0020, Hazardous Waste Fees, 3M has been assessed a permit re- issuance application fee of .$106,370 This fee was calculated based on the activities associated with thermal treatment and storage of hazardous waste at the 3M Cottage Grove Center facility, and is enclosed with this application. The fee was calculated using the following procedure: The table and instructions for the fees can be found in the state regulations, 7046.020 Subpart 1 Permit application fee for a thermal treatment unit: 20% of the fee for tanks and outside storage: 20% of the fee for a waste pile — for the ash storage: TOTAL For a permit renewal the total is divided by 2 This figure is multiplied by 2.79, a factor set by the legislature This figure is rounded off to the nearest $10 for the final fee: $72,390 $964 $2,896 $76,390 $38,125 $106,368 $106,370 R -1 3M Section S1 1/17/12 SECTION S Section S describes the five types of waste management units operated at the 3M Cottage Grove Center facility. These include the following: Container Storage Areas Section S1 Tank Storage Section S2 Containment Storage Section S3 Incinerator Section S4 Decontamination Area Section S5 SECTION S1 CONTAINER STORAGE SIA CONTAINER STORAGE INTRODUCTION The container storage section for the 3M Cottage Grove Corporate Incinerator describes where hazardous waste is stored in containers and outlines how those containers are handled. Containers are managed in accordance with Minnesota Administrative Rules (M.R.) Part 7045.0526. This section provides the information required by M.R. Part 7001.0570). Section S1 is divided into several parts: • Section S1.2, CONTAINERS, TANKER TRUCKS & TRUCKS RECEIVED, describes containers in which hazardous waste may be received. • Section S1.3, CONTAINER STORAGE AREAS, provide information on the storage capacity of each of the areas used at the Corporate Incinerator to store hazardous wastes. • Section S1.4, DESCRIPTION OF CONTAINER STORAGE AREAS, provides detailed information on each container storage area. • Section S1.5, INFORMATION ON CONTAINER TYPE, WASTE TYPE AND COMPATIBILITY, provides information on the types of containers used, and the compatibility of wastes and their containers. • Section S1.6, HAZARDOUS WASTE CONTAINER OPERATIONS, describes procedures used to assure proper management of hazardous waste containers. • Section S1.7, REQUIREMENTS OF M.R. 7045.0526 describes how the regulated storage areas at the facility are managed so as to comply with specific parts of this regulation. S-1 3M Section 31 1/17/12 S1.2 CONTAINERS, TANKER TRUCKS AND TRUCKS RECEIVED Hazardous and nonhazardous wastes are transported to the Cottage Grove Corporate Incinerator by truck in a variety of DOT approved containers, in tanker trucks, as well as in truck shipments of bulk materials. All permitted storage areas may store the waste codes listed in Table B -1. S1.2.1 Containers Hazardous wastes are shipped to the incinerator in DOT approved drums or other approved containers including overpack drums, portable tanks, boxes, fiber and plastic drums, bags, and pails. Container selection, packaging, and labeling are specified for each waste in the waste stream profile. Such wastes may be received and stored in several areas, as described in this section. Section C.10 describes the computerized waste tracking system. Labels on the hazardous waste drums indicate whether each drum contains pumpable (free liquid) or non - pumpable (minimal free liquid) waste. When containers are unloaded, operating personnel segregate the drums by type of waste (see Section S1.6 and Section A.3). The drums are then loaded into storage trailers, although in some cases drums may go directly to the incinerator. When a storage trailer has been filled, it is moved from the incinerator dock to a permitted trailer storage area. These storage areas are described in this section. S1.2.2 Tanker Trucks Hazardous waste liquids are also received in tanker trucks. Tanker truck shipments are off - loaded in the Tanker Unloading Building, Building 136. Wastes are analyzed for fingerprint parameters and then pumped into an appropriate storage tank. Each of these storage areas is permitted to store all waste codes listed in Table B -1. Bulk tankers may only be stored in the following areas: • Building 136 • Building 77 Containment Area • Lot C • Lot a South S1.2.3 Bulk Solids Materials Bulk solids shipments of hazardous and nonhazardous waste are handled as special projects requiring MPCA approval before unloading into the Containment Building 181. Bulk material storage and handling is described in Section S3, Containment Building. S-2 3M Section S1 1/17/12 SU CONTAINER STORAGE AREAS The permitted container storage areas are listed in Tables S -1 and 2 below. Storage capacities are based on a nominal trailer storage capacity of 88 drums and 50 gallons per drum. Actual container types and capacities may vary. Tanker capacity is based on 6,500 gallons per tanker. If a storage area may hold fewer drums or less liquid than the maximum storage capacity indicated below, the number of drums containing free liquid (or gallons of free liquid) that may be stored in an area is indicated in parentheses. Secondary containment volumes are not listed for the trailer storage areas where truck liners are used to provide spill containment. TABLE S -1 CONTAINER STORAGE AREAS Lot Number Maximum Storage Capacity in Drums Maximum Storage Capacity in Gallons Secondary Containment Volume in Gallons A 9,152 or 4,400 North with 54 tankers South 467,600 or 220,000 North with 351,000 South North half provided by trailer liners South half provided by coated concrete and sump (Capacity 340,655 gallons) B 616 30,800 Provided by trailer liners C 3,520 or 40 Tankers 176,000 or 260,000 Coated concrete and sump with a capacity of 200,000 gallons D 5,456 272,800 trailer liners E 5,896 294,800 Provided by trailer liners F 5,104 255,200 Provided by trailer liners J 6,600 330,000 Provided by trailer liners K 440 22,000 Provided by trailer liners L 1,408 70,400 Provided by trailer liners M 8,448 422,400 Provided by trailer liners Subtotal 38,192 or 29,920 and 94 Tankers 1,909,600 2,107,000 Lots L and M are used to store only non hazardous wastes S-3 3M Section S1 1/17/12 TABLE S -2 BUILDING STORAGE AREAS Building Location Maximum Storage Capacity in Drums Maximum Storage Capacity in Gallons Secondary Containment Capacity in Gallons Building 47/60 - Dock Stalls 12 Trailer Spaces 1,056 52,800 Provided by trailer liners BUILDING 47 Pak Feeder Area 48 2,400 264 Pump Room 32 1,600 264 Staging and Storage 500 25,000 4,326 Totals — Bldg. 47 580 29,000 5,735 BUILDING 60 Receiving Area 240 12,000 3,070 Storage Area 1 16 800 93 Storage Area 2 20 (10) 1,000 (500) 58 Storage Area 3 20 (10) 1,000 (500) 57 Storage Area 4 52 (25) 2,600 (1,250) 139 Storage Area 5 20 (10) 1,000 (500) 58 Storage Area 6 60 (15) 3,000 (750) 84 Drum Inspection and Sampling Area 34 1,700 489 Totals for Building 60 462 (70) 23,100 (3,500) 3,559 BUILDING 145 Dock Stalls - 4 Trailer spaces 352 17,600 17,027 Main Floor Area 1 Direct Burn Room 32 1,600 310 Area 2 — Sludge Room 48 2,400 1,310 Area 3 — Drum storage outside the sludge room by conveyors RR and ZZ 92 4,600 1,180 Area 4 — Drum Handling Conveyors Al, A2, B1, B2 24 1,200 490 Area 5 — Pak Drum Inspection Conveyors C1, C2, D, E 4 200 785 S-4 3M Section S1 1/17/12 TABLE S -2 BUILDING STORAGE AREAS Continued Building Location Maximum Storage Maximum Storage Secondary Containment Capacity in Drums Capacity in Gallons Capacity in Gallons Area 6 Pak Feeder Drum 4 200 330 Directing Conveyors F, S Area 7 — Drum Storage and Pak/Komar Queue Conveyors 1-11 -4, J1 -4, K1-4, L, M, N, 408 20,400 4,807 O, P,Q, R, Y, Z, AA, BB, MM, PP, QQ Second Floor 60 3,000 1,450 Area 1 — Komar Staging Lower Level 12 600 1,270 Sludge Processing Area 1 Staging Area 2 - Staging 2 100 590 Totals Building 145 1,038 51,900 29,549 Building 77 — Dock Stalls 176 or 2 Tankers 8,800 or 13,000 8,110 Drum Storage 76 3,800 Building 136 — Dock Stalls 176 or 2 Tankers 8,800 or 13,000 23,260 Drum Storage 76 3,800 Total Drum Storage for All 3,640 or 182,000 or Buildings 3,288 and 4 Tankers 190,400 Total Volume for All Buildings, 41,832 or 2,091,600 Trailers and Tankers 33,208 and 94 2,297,400 Tankers A schematic of the hazardous waste storage areas is in Drawing No. CHEM- 888 -C -142 in Appendix A. S1.4 DESCRIPTION OF CONTAINER STORAGE AREAS S1.4.1 Incinerator Material Handling Buildings Hazardous wastes are transferred to and from Building 47 and or 60 through one of twelve docks on the east side of Building 47 and 60. Containers are removed from trailers on pallets or individually. Containers are managed as described in Section S1.6: Hazardous Waste Container Operations. Containers may also be stored in trailers located at the dock doors. Container management practices are described in greater detail below. S-5 3M Section S1 1/17/12 Interior Areas of Building 47/60 Building 47/60 is described in Figures S1 -1 and S1 -2, located in Appendix S1. These buildings are segregated into the following processing and work areas: (1) Building 60 Receiving Area (2) Building 60 Storage Area (3) Building 47 Pumproom (4) Building 47 Former Pak - feeder Area (5) Building 47 Storage and Staging Area. The Building 60 Receiving Area and Building 47 Storage and Staging area are used to evaluate incoming shipments and prepare shipments for off -site disposal. The Building 47 Pump room is used for waste processing. The Building 47 Pak - feeder area is used for waste storage. The Building 60 Storage Area is utilized for extended waste storage. The floors of all areas are constructed with concrete. Concrete surfaces are treated with penetrant coatings to provide both chemical resistance and a non - sparking surface and is used in those areas where flammable material containers are opened. Floor trenches and sumps are shown in Figures S1 -1 and S1 -2 (Appendix S1). Secondary containment calculations are also included. The Building 60 Receiving Area has trenches and a 600 gallon sump with a combined secondary containment capacity of 3,380 gallons. The secondary containment provided is more than adequate to retain ten percent of the maximum liquid contents or the entire liquid content of the largest container stored in this area. The Building 60 Storage Area consists of discrete areas segregated by concrete curbs and having individual floor trenches. In addition to these discrete storage areas, this portion of Building 60 provides space for staging waste for waste analysis sampling. The storage capacities and secondary containment volumes are provided in Figure S1 -1 (Appendix S -1) with additional information in the first section of Appendix S1. The Building 47 Pak - feeder Area, Storage and Staging Area, and Pump Room all have separate trenches and floor drains. The secondary containment provided in the floor trenches and sumps are 226, 5,741, and 1,002 gallons, respectively. All secondary containment capacities are sufficient to hold 10% of the liquid contents stored in these areas. 1 3M Section S1 1/17/12 Building 47/60 Dock Area The exterior of the twelve Building 47/60 docks is constructed of concrete. A trench is provided along the length of the building, and the area slopes toward this trench. The trench feeds to a concrete secondary containment sump behind Building 60. Dock areas are continually under the observation of the operators during use. Sufficient absorbent materials are immediately available to contain a spill in this area. The design and use of the trailers is described in greater detail in Section S.1.4.3 Interior Areas of Building 145 Building 145 is divided into the following processing and work areas: Main Level 1) Area 1 - Direct Burn Room 2) Area 2 - Sludge Room 3) Area 3 — Drum Storage 4) Area 4 — Pak Drum Handling Conveyors 5) Area 5 — Pak Drum Inspection Conveyors 6) Area 6 — Pak Drum Directing Conveyors 7) Area 7- Drum Storage and Pak/Komar Queue Conveyors Lower Level 1) Area 1 - Sludge Pump Tanks and Staging Area 2) Area 2 - Sludge Pump Staging Area Upper Level 1) Areal - Komar Staging Detailed information about these areas is found on drawings S -3, S -4 and S -5 and CHEM- 145 -A -121, 122, and 123 included in Appendix S1 along with secondary containment calculations for these areas. The floors of all areas are constructed with concrete. Concrete surfaces are treated with penetrant coatings to provide both chemical resistance and a non - sparking surface and is used in those areas where flammable material containers are opened. Floor trenches, curbs, and sumps are shown on the Building 145 drawings in Appendix S1. All Building 145 secondary containment areas overflow through a 390 gallon vertical sump into a 12,000 gallon containment tank located outside the Building All secondary containment capacities with the exception of Area 1 on the Lower Level are sufficient to hold 10% of the liquid contents or the entire liquid content of the largest container stored in these areas. Area 1 on the Lower Level has a secondary containment capacity of 1,270 gallons and includes two 2,150 storage tanks for sludge processing. Additional containment for this area, as S-7 3M Section S1 1/17/12 well as for all containment areas, is provided by the 12,000 gallon underground containment tank located directly outside the Lower Level sludge processing areas. Building 145 Dock Area The exterior of the four Building 145 docks is constructed of Portland cement concrete treated with a protective coating. A canopy over the dock area provides protection against precipitation. The secondary containment volume for the Building 145 docks is 4,637 gallons. Additional containment is provided by the 12,000 gallon underground containment tank. Dock areas are continually under the observation of the operators during use. Sufficient absorbent materials are immediately available to contain a spill in this area. The design and use of the trailers is described in greater detail in Section S.1.4.3 S1.4.2 Trailer Staging Areas - Lot C and Lot A South Lot C and Lot A South are used as staging areas for trailers and tankers after they arrive at the site and prior to waste receipt and unloading. Each incoming shipment is staged for a period not exceeding ten days, the time period allowed for the reconciliation of major manifest discrepancies. The areas may also be used for the permitted storage of any other trailer providing that compatibility requirements are met. These areas are visited and observed daily by facility staff. S1.4.3 Trailer Storage Lots A B D E F J K L and M Containers of hazardous waste are stored in dedicated semi - trailers in nine permitted trailer storage areas. Lots A (north) and D are clay - lined. The south half of Lot A has concrete secondary containment and is coated with a chemically resistant coating. Lots B, K, and L are constructed with clay and synthetic liner systems. These lots are also bermed to contain run -off and spills and prevent run -on. Several of the pads have 8 ft. wide concrete strips that are used to support the front dolly trailer supports. Lot M is constructed of class 5 crushed rock and is used to store non - regulated waste only. Secondary containment in Lot M is provided by internal secondary containment in the storage trailers. Lot J is a clay -lined lot used only as a non - hazardous waste trailer storage area. S1.4.4 Trailer Containment Liners Any trailer containing liquid hazardous wastes stored in Lots A north, B, D, E, F, and K, L, and M for a period exceeding 24 hours must have internal secondary containment. This is provided with containment pallets or with a containment liner. Plans, specifications, and containment liner design criteria are provided in Appendix S1. Liner secondary containment is achieved by orientating the front of the trailer downward at a specified slope and by maintaining trailer side slopes within specified limits. Design calculations describing the effects of front -to -back and side slope are provided in Appendix S1 for a 45 foot long trailer with drums placed on pallets. An 3M Section S1 1/17/12 The liners are constructed of fourteen gauge (0.0747 inch) diamond plate steel sheets formed on the sides to provide the necessary containment. The seams are then overlapped and welded in place. The material is sufficient to contain chemical spills until they are discovered and remedied. Trailers stored at the Building 47/60/145 dock doors are also subject to these containment requirements. Containment requirements do not apply in waste management areas when the residence time of a hazardous waste container is less than 24 hours. This includes the trailer's being transported between storage areas and loading /unloading areas. S1.4.5 Drum Configuration and Inspection in Trailers Container configuration during storage allows 3M to inspect the trailers for leaking containers or container deterioration on a weekly basis. In general, drum pallets are positioned down the center of the trailer allowing inspection on either side of the pallets. Drums placed in trailers and transported to on -site storage areas are placed and handled in a manner that prevents unnecessary drum movement or tipping during transportation. Safeguards that are taken include the following: (1) All top -tier pallets are bound with strapping tape, shrink wrap, or equivalent mechanism to prevent drums from shifting or falling off pallets. (2) Double- stacking is permitted only if the lower pallet provides a level surface for placement of the upper pallet. (3) A ten mile per hour speed limit is required for all transportation within the plant site. (4) The entrances to all storage areas are ramped to prevent trailer tipping. S1.4.6 Building 77 - Drum Staging Building 77 is an outdoor covered container storage area next to the Tanker Unloading Building 136. This secondary containment area provides additional storage for bulk tankers when Building 136 is unavailable. This area is also used to unload trailers suspected of having a leaking container. In this case, the trailer is managed according to the following sequence: a. The trailer is pulled up to the Building 77 dock. Care is taken to contain any spilled material during container movement. b. The trailer is ventilated. c. The drums are unloaded in the container storage area. d. The leaking container is located and repaired and /or overpacked. e. The trailer and containment liner are cleaned. S-9 3M Section S1 1/17/12 f. The drums are reloaded onto a trailer. g. The trailer is returned to a permitted storage area. This area is open on all four sides but is equipped with a roof. The impervious concrete floor in this storage area is bermed to hold spills and leaks. The concrete floor is sealed with a flexible elastomeric sealant. Run -on and run -off are prevented by the secondary containment berm. This storage area is inspected daily. Precipitation is pumped out of the area, since the berm has no outlet. Spilled material is removed promptly. The following information is included in Appendix S1. (1) Drawings showing construction details, including floor slopes, trench drain details, construction joints, etc. of the storage and dock areas. (2) A drawing showing a container storage configuration. All waste types and waste codes listed in Table B1 may be stored in this area. (3) Secondary containment calculations. S1.4.7 Building 136 - Tanker Unloading Building Bulk tankers are stored in Building 136 while wastes are being transferred into one of the hazardous waste storage tanks. Occasionally, the contents of the tankers are transferred into drums or tote tanks. . Containers may be stored in Building 136 while the contents are transferred into a tank or bulk tanker for transportation to an off -site facility. The Tanker Unloading Building is described more fully in Section S2.6. The following information is included in Appendix S1. (1) Drawings showing construction details, including floor slopes, trench drain details, construction joints, etc. (2) A drawing showing a container storage configuration. All waste types and waste codes listed in Table B1 may be stored in this area. (3) Secondary containment calculations. S1.5 INFORMATION ON CONTAINER TYPE, WASTE TYPES & COMPATIBILITY The 3M Cottage Grove Corporate Incinerator is currently permitted to accept a wide variety of hazardous and non - hazardous wastes. As described in Section C, Waste Analysis Plan, each waste stream sent to the Corporate Incinerator must have a waste stream profile that has been approved. Among the information specified in the waste stream profile are the approved DOT container type(s) and size(s) for each waste. All containers are compatible with the waste and in good condition. S -10 3M Section S1 1/17/12 S1.6 HAZARDOUS WASTE CONTAINER OPERATIONS 3M has established procedures to handle, transport, label, and dispose of hazardous and non - hazardous wastes in accordance with all applicable requirements. All employees working at the incinerator are trained to understand the potential hazards associated with the contents of the drums or containers and to follow the established procedures. Shipments of hazardous waste arrive at 3M Cottage Grove from off -site locations via licensed hazardous waste transporters and are received at Building 47/60. Containers are unloaded at a dock and inspected for damage and manifest verification. Containers on pallets and are unloaded using a forklift. Before being moved, all containers are inspected by the forklift operator to assure that they can be moved safely. Containers may be placed in a staging area in Building 47/60 or Building 145 for immediate incineration, or reloaded onto dedicated storage trailers and moved to one of 3M's permitted container storage areas. Containers are eventually moved to either the Building 47/60 or the Building 145 docks, moved to a staging area, and fed into the incinerator. Site operations are organized to minimize the amount of drum and container movement required at the incinerator. The movement of each hazardous waste container is tracked by a computerized electronic bar coding system, as described in Section A.3 of the Permit Application. Drum or container staging areas at the incinerator are kept to the minimum number necessary to identify and classify materials safely and to prepare materials for transport off -site or incineration on -site. Pallets of containers are placed in the staging area in designated areas only. Adequate aisle space is maintained between containers. Main aisles for the forklift trucks are always maintained in front of the loading docks, to and from the pump room, to the adjacent warehouse, and directly in front of the drum feeder conveyor. Drums and containers used during spill cleanups meet all appropriate DOT, OSHA, and EPA regulations for the wastes they contain. Drums and containers are inspected, and container integrity is assured prior to being moved. 3M maintains a supply of salvage drums and containers that meet (DOT) specifications. 3M also maintains suitable quantities of spill clean up materials, available for use in areas where spills or leaks may occur. Information on the location and contents of spill clean up carts is provided in the incinerator facility's Emergency Response Guide. Drums and containers used to ship hazardous waste off - site are DOT approved. S-11 3M Section S1 1/17/12 The 3M Cottage Grove Corporate Incinerator uses appropriate material handling equipment for the transfer drums and containers to minimize sources of ignition, as described in Section I. S1.7 REQUIREMENTS OF MINNESOTA RULE 7045.0526 All of the Building 47/60 and 145 container management areas and the trailer storage lots described above are regulated storage units and are subject to the requirements of Minn. Rule 7045.0526. Comments pertaining to specific parts of that rule are provided below: 7045.0526 - Subpart 4: Management of Containers , Containers holding hazardous waste are always kept closed during storage, except during waste sampling, transfer, or processing. Containers are not opened, handled, or stored in a manner that might rupture the container or cause it to leak. Containers are also clearly labeled. If the labels are not legible, additional labels are added by incinerator personnel. Containers in trailer storage lots are stored inside trailers to prevent exposure to moisture or direct sunlight, thus ensuring that these factors do not affect the container's ability to contain the waste. Containers are stored with one row of pallets down the center of the trailer, stacked two pallets high. This leaves the labels on the sides of the drums unobstructed. 7045.0526 - Subpart 5: Inspections All waste container storage areas inside buildings are inspected daily for container integrity, leaking containers, and secondary containment integrity. Inspections are documented in the facility operating record. Trailers are inspected on a weekly basis for any evidence of leaks from the containers, deterioration of the containers, and deterioration of the containment structure in the trailers. The inspections are logged. Whenever deterioration or leaks are detected, all the requirements of Part 7045.04542, Subpart 5, Item D are addressed. 7045.0526 - Subpart 6: Secondary Containment The secondary containment systems for building storage areas are discussed above in section S1.4. All areas are coated concrete providing secondary containment. All floors are free of cracks and gaps and are sloped to drain liquids to area floor trenches. Trenches and sumps all have sufficient volume to contain 10% of the liquid waste contents. The number of drums listed for each area of Building 60 is not limited by the available secondary containment but was determined by spatial storage limits. The secondary containment available will limit the S-12 3M Section S1 1/17/12 number of drums stored in any particular area when that storage exceeds 24 hours. This issue is addressed during daily inspections. Portable containment pallets may be used to increase secondary containment capacity. Secondary containment for trailer storage areas is described below: • All container storage areas currently have a containment system that is capable of collecting and holding spills, leaks, and precipitation. All trailers used to store containers holding waste with free liquids are equipped with steel liners. The liners are maintained free of cracks or gaps and sufficiently impervious to collect and hold spills, leaks, and precipitation. • Containers are stored on pallets that keep them elevated and prevent their contact with any accumulated liquids. • The trailer liners are designed and used in a manner that will contain ten percent of the volume of the containers in the trailer or the largest container, whichever is greater. • Run -on into trailers is prevented because they are elevated off the ground. • Any spilled or leaked waste or accumulated precipitation is removed in a timely manner. If the collected material is a hazardous waste, it is managed as a hazardous waste in accordance with applicable requirements. 7045.0526 - Subpart 7: Special Requirements for Ignitable or Reactive Wastes All waste container storage and handling areas are at least 700 feet from the facility's property line, as outlined in Section 1.3. As outlined in Section S1.4.1 and 1.3, containers are segregated during storage to prevent potential reactions of ignitable or incompatible wastes. Segregation and separation of each hazardous waste is consistent with 49 CFR Subpart C Segregation and Separation Chart of Hazardous Materials (177.848). 7045.0526 - Subpart 8: Incompatible Wastes As outlined in Section S1.4.1 and 1.3, containers are segregated during storage to prevent reactions of ignitable or incompatible wastes. The Incinerator Waste Tracking System uses segregation logic consistent with 49 CFR Subpart C Segregation and Separation Chart of Hazardous Materials (177.848) to identify potentially incompatible wastes in storage trailers or inside the process buildings. Incompatible materials are not stored in areas that have a shared secondary containment system. Compliance with compatibility requirements is maintained by storing wastes in areas with separate secondary containment or through the use of containment pallets, overpacks, or other similar containment devices. Any container processed through a process or work area in less than 24 -hours is exempt from segregation requirements. S -13 3M Section S2 12/18/09 SECTION S2 TANK STORAGE S2.1 INTRODUCTION Tanks are used at the facility to blend or decant liquid hazardous wastes, and to store them prior to incineration. The storage tank system contains 10 permitted hazardous waste storage tanks. There are eight 18,360 gallon tanks, one 200,000 gallon tank, and one 10,000 gallon decant tank. Each tank has a primary purpose, although any of the tanks is capable of blending and storing any waste handled at the incinerator and piping from the tanks is designed such that any of the tanks can feed waste to the kiln. 3M stores wastes with all of the hazardous waste codes listed in Table B -1 in these hazardous waste storage tanks. The location of the tanks is shown in Appendix A, Figure CHEM- 888 -C -142 S.2.2 Secondary Containment All tanks, with the exception of Tank 1 and the sludge tanks, are grouped in a sealed concrete containment structure with a capacity as indicated Table 1. Tank containment meets the RCRA requirements of secondary containment in 40 CFR 264 Subpart CC. All the tanks, with the exception of Tank 1, are above grade, and on legs, allowing for leak detection and spill response directly under each tank. Each containment structures storage capacity exceeds the storage volume of the largest tank in the structure, plus sufficient allowance for precipitation. Drawings containing the construction details specified under 7045.0528, subpart. 4, Items B, C, D, E, and H are included in Appendix S2. Secondary containment calculations are also included. All tank systems and ancillary piping are inspected daily. Tank 1 is provided with steel secondary containment, with an annular design. The capacity of the structure sufficiently exceeds the volume of the tank to provide for containment of precipitation. Additionally, Tank 1 is constructed with a double bottom and synthetic liner to allow for detection of leaks from the bottom. Three leak detection ports are provided and are inspected daily. The tank meets the corrosion protection requirements of MR 7045.0528 Subpart 3.F. Emissions from Tank 1 are controlled by a flare, as described in Sect. T of this application. The two sludge tanks are located in an area on the lower level of Building 145 with a secondary containment volume of 1,270 gallons. The lower level sludge area, along with the other areas in Building 145 where waste is processed or stored, drains through a 390 gallon vertical sump to a 12,000 underground overflow tank. (See drawing CHEM- 145 -A -121 in Appendix S -1 and drawings CHEM- 888- C -630F and T -6235 in Appendix S2.) S -1 3M Section S2 12/18/09 All piping and ancillary equipment without secondary containment have been constructed with welded flange joints that are above ground and inspected daily. Piping with threaded fittings may be present within the tank containment structure or at the kiln frontwall area. Both areas are provided with secondary containment. Additional tank design specifications and dimensions are provided in Appendix S2. S2.3 DECANT TANK The 10,000 gallon decant tank is used as a waste storage and phase separation tank. Tank level is monitored via the control systems displays, an indicator in the Building 47 pump room, an indicator in the Tanker Unloading Building and an indicator on the decant tank. A decant tank high level alarm is generated should the tank reach 95% of its capacity. S2.4 WASTE STORAGE TANKS Bulk tankers may be unloaded directly into any one of the waste storage tanks. Waste storage tank level is monitored via the control system displays, an indicator in the Tanker Unloading Building, and an indicator at the base of the respective tank. A high level alarm is generated if any tank level reaches 95% of capacity. The capacity of each tank allows for greater than two tank trailers of material storage, providing safe material handling and reducing the risk of overfills. Additionally, each tank is provided with redundant means of overfill protection /level control. Waste storage tank level is monitored via the control system displays, an indicator in the Tanker Unloading Building, and an indicator at the base of the respective tank. A high level alarm is generated if any tank level reaches 95% of capacity. Three tanks are provided with heat tracing and insulation for storing aqueous wastes, but are not necessarily limited to aqueous wastes. S2.5 SLUDGE TANKS - BUILDING 145 Two 2,150 gallon tanks are used to process sludge in the Building 145 sludge room. Under normal operations, containers of highly viscous waste are inverted onto a grid above a trough that feeds the sludge batch tank. When the batch tank is full, its contents are transferred to the feed tank. A sample is collected at the sample port in the sludge transfer /recirculation line. The system also provides for creating a sludge batch by draining waste directly from the trough into the sludge feed tank. S -2 3M Section S2 12/18/09 The sludge tanks are constructed of steel according to ASME code, Section VIII, Division 1 95E/97A for a design pressure of 50 psig. The sludge tank system has been reviewed and certified by an independent, qualified, registered professional engineer as to structural integrity and suitability for handling hazardous waste. Instrumentation for the tanks includes high and low level switches. Sludge tank specification and dimensions are included in Appendix S2. The hazardous waste tank capacity at the 3M Cottage Grove Incinerator, grouped by secondary containment area, are: TABLE 1 - TANK AND CONTAINMENT CAPACITY Tank Capacity Containment Capacity Tanks Gallons Gallons Decant Tank 20 10,000 38,930 Tank 1 200,000 228,000 Tank 21 18,360 46.850 Tank 22 18,360 46,850 Tank 23 18,360 46850 Tank 24 18,360 46,850 Tank 25 18,360 46,850 Tank 26 18,360 46,850 Tank 27 18,360 46,850 Tank 28 18,360 46,850 Sludge Batch Tank (Building 145) 2,150 13,660 ** Sludge Feed Tank (Building 145) 2,150 13,660 ** ** Includes area containment (1,270 gallons), containment sump (390 gallons), and underground containment tank (12,000 gallons) S -3 3M Section S2 12/18/09 S2.6 TANKER UNLOADING BUILDING 136 The contents of tanker trucks drums and totes may be transferred directly into a , decant or storage tank from the Tanker Unloading Building 136. The contents of tankers may also be transferred into drums or totes in this area. Building 136 is contained within a sloped, containment area with a capacity of 10,000 gallons. This area is sufficient to contain the largest tanker volume of 7,000 gallons. Two pumps located in Building 136 are used to transfer liquid wastes or No. 2 fuel oil from incoming tanker trucks to the tank farm. The pumps may also be used to pump waste from a waste storage tank to a tanker. The pumps stop automatically if a high level is sensed in any of the storage tanks. S2.7 TANK INSPECTION AND MONITORING Hazardous waste tanks and their associated piping, connections and valves are visually inspected daily for leaks. The containment structures are also examined daily for integrity and evidence of tank leaks. These inspections are logged on a daily basis. Inspection logs are kept on file. If water is present in the containment area, it is noted on the Daily Operating Log After visual inspection the water is pumped to the neutralization system for wastewater pretreatment. If there are indications that the water may be contaminated with waste materials, the water is collected by vacuum truck, drained to drums, and incinerated. Tanks are continuously monitored in the control room by the operator. Tank levels are also continuously monitored. Tank level alarms and tanker unloading alarms are displayed and printed in the control room. S2.8 TANK CORROSION AND EROSION All tanks were designed with corrosion allowances as listed in the applicable specification. On a regular basis, tanks are tested for metal wall thickness and visually inspected for corrosion inside and out. Tank inspections records are kept on file. Since the hazardous waste tanks, other than Tank 1, rest on concrete and steel columns elevating them several feet above the ground, any leak would be easily spotted. Tank 1 is an on -grade tank with a double bottom designed to provide leak detection. Should any tank develop a leak, it will be immediately taken out of service, emptied, cleaned, inspected and S -4 3M Section S2 12/18/09 checked for remaining metal thickness and the cause of the leak. It will then be repaired or replaced before being returned to service. Containment dikes, constructed of coated Portland cement, are sealed with a chemical resistant epoxy coating to prevent containment structure damage and leaks. S2.9 TANK MANAGEMENT PRACTICES Incompatible pumpable wastes received at the facility are stored in separate tanks or containers. When waste is received on -site, an evaluation is performed to determine its compatibility with other wastes before placing it in a storage tank. If it is determined that the waste must be stored in a separate empty tank, a check is made to determine the composition of previously stored waste. If the wastes are not compatible, the tank is cleaned to remove any residual waste from the tank. Tank cleaning involves spraying the inside of the tank with a high pressure washer and removing the aqueous solution. This solution is then drummed for on -site incineration. S -5 3M Section S3 -Rev.1 10/05/11 SECTION S3 CONTAINMENT BUILDING S3.1 INTRODUCTION This section describes the process operations that are conducted in the Bulk Solids Containment Building 181. Containment Building 181 is used primarily to stage ash residues from the incineration process prior to shipment off site. With MPCA approval, the building could also be used for receiving bulk solids, such as soil, that could be unloaded into the Containment Building and repackaged for processing in the kiln. S3.2 Containment Building Compliance with Subpart DD Regulatory Requirements This section outlines how Building 181 fulfills the Containment Building requirements found in 40CFR, 264 Subpart DD (40 CFR264.1101 (a), (b), and (c)). (a)(1) Building 181 is enclosed by floors, walls, and a roof to prevent exposure to the elements. (a)(2) The floor of the Building is constructed of one -foot four -inch thick reinforced concrete. The walls are constructed of one -foot thick reinforced concrete. The concrete has sufficient structural strength to support bobcat loaders, forklifts, end dumps, roll -off boxes, and other containers that may be placed in these areas. The slag /ash is not chemically reactive and is compatible with the concrete surfaces. The building has garage and pedestrian access doors and windows. This unit is designed and operated in such a fashion that waste will never come in contact with these openings. (a)(3) Incompatible wastes or treatment reagents will not be placed in this area. (a)(4) The concrete floor in this building is the primary barrier. It is designed to withstand the movement of personnel, waste, and handling equipment in the unit during the operating life of the unit. The concrete barrier is appropriate for the physical and chemical characteristics of the waste to be managed. (b) The building is designed to store Incinerator ash, which, although nominally dry, may have a moisture content estimated at 1 to 5 percent. As the ash sits, a very small amount of water will seep out of the ash pile over time. (b)(1) The primary barrier is constructed of concrete that has been treated with a chemically compatible sealant to prevent the migration of hazardous constituents into the concrete. Major joints between metal walls and concrete curbs have been treated with a protective sealant. Application of these sealants is repeated at least annually to prevent deterioration that could impair the containment capability of this building. S -1 3M Section S3 -Rev.1 10/05/11 (b)(2) The building floor is sloped to contain any water that seeps out of the ash, which is then collected and removed by personnel responsible for ash handling or by the Incinerator operators during routine shift inspections. If water is present, it shall be collected and removed from the floor of the building a minimum of once per day, or whenever the quantity of free liquids is estimated to be greater than 31 gallons, for subsequent treatment and disposal.The water may be initially transferred to a container for storage. The water is then transferred from the vacuum system or from a storage container into the Incinerator wastewater treatment system. (b)(3) An approved secondary containment system has been installed in the building. The secondary containment system consists of a 40 mil thick high density poly liner secondary barrier that underlies the concrete floor primary barrier, and a leak detection system between the primary barrier (concrete floor) and the secondary containment barrier (synthetic liner) that is capable of detecting a failure of the primary barrier. Both the concrete floor and the synthetic liner are sloped to a low point along the west wall to facilitate liquid detection and removal. This leak detection system, described as follows, provides continuous and automatic leak detection within the secondary containment liner: • A concrete structure has been installed outside the west wall of the building, corresponding to the low point of the secondary containment. The purpose of the structure is to allow access to the leak detection system. • A drain line is installed in the secondary containment liner, terminating within the concrete structure. This line is provided with a blind flange and a valve, in the unlikely event that it becomes necessary to remove water from the secondary containment liner. • The drain line is equipped with an electronic liquid detector. This detector is continuously monitored by the Incinerator control system. Detection of liquid by the monitor would cause an immediate alarm to the Bldg. 145 control room operator. The detector is subject to periodic maintenance and testing according to a specified schedule. The drain line is also provided with a sight glass that is inspected regularly for the presence of visible liquid. (c)(1)(i) The following procedures are in place to ensure there has not been degradation or deterioration of the floor that would impair the containment capability of the building: • A visual inspection of the exposed area of the floor is conducted on a daily basis. • A visual inspection of the floor area is conducted after ash is removed for ash shipment, which typically occurs at least once per week. S -2 3M Section S3 -Rev.1 10/05/11 • A full cleaning and inspection of the entire floor of the building is conducted on a semiannual basis. (c)(1)(ii) The elevations of bulk wastes stored in this building will always be less than nine feet, the elevation of the metal containment walls. (c)(1)(iii) Bobcats and dump trailers are routinely moved in and out of this building. The tracking of waste out of the building is prevented by cleaning the floors before equipment enters the building or by cleaning equipment as it leaves the building. Consequently, tires in contact with the concrete floors are not in contact with the waste, and no further cleaning is necessary. Any waste inadvertently tracked out of the unit is immediately collected and returned to the building. Materials generated as a part of equipment cleaning are managed appropriately. Rear end gates and tires that may have come into contact with the waste are cleaned with brushes and brooms before exiting. A HEPA -type vacuum cleaner is used to thoroughly clean bobcat loaders and end -dump tires before they exit the building. During removal of wastes from the unit for off -site shipment and disposal, tracking of wastes outside of the unit is prevented by the methods described above or by using separate front -end loaders inside and outside the building. In the latter case the tires of the front -end loader outside the building are not in contact with the waste. (c)(1)(iv) After being processed through the quenches, the incinerator slag /ash contains sufficient water that it does not produce dust or fugitive emissions while being processed or transferred. Fugitive emissions, as determined by 40 CFR Part 60, Appendix A, Method 22, are not present during normal materials handling. Wastes whose handling could produce fugitive emissions as determined by Method 22 are not processed in the Building 181. Liquid dust suppressants may be used to control emissions during waste handling or equipment operation. (c)(2) The professional engineer's certification is included in Appendix S3. (c)(3) 3M will correct any condition that could lead to a release of hazardous waste in accordance with the requirements of this part. (c)(4) The floor of Building 181, the area adjacent to the building, and the leak detection system sight glass are visually inspected at a minimum once every seven (7) days for evidence of a release of hazardous wastes, or failure of the primary barrier. A record of the inspection and any S -3 3M Section S3 -Rev.1 10/05/11 deviations from normal conditions are noted in the facility operating record. Alarms from the leak detection system are maintained in the Incinerator process control system database. S -4 3M SectionS4 12/18/2009 SECTION S4 ENGINEERING DESCRIPTION OF INCINERATOR This permit application does not include detailed information on the incinerator design, pollution control equipment design, control efficiencies, operating parameters, or estimated emissions. These issues are addressed by a Title V air permit. The 3M Company owns a corporate incinerator, including associated container and tank storage areas, in Cottage Grove, Minnesota. 3M operates this facility to provide treatment and storage for business - related wastes, including organic and inorganic hazardous wastes, generated by 3M's operating divisions throughout North America and from non -3M sources. 3M Cottage Grove Center is classified as both a generator and a treatment/storage facility in accordance with the 1976 Resource Conservation & Recovery Act. No waste disposal is conducted on the site. The current federal and state TSDF permits cover the corporate incinerator, container storage areas and bulk tank storage for the management of hazardous wastes. The capacity of the incinerator system is nominally 120 million BTU /hr as determined by the maximum gas flow in the stack of 40,000 dry standard cubic feet per minute. Materials are received and processed as containerized solids, sludges, liquids, and gases, bulk liquids and bulk solids. Waste materials are fed into a rotary kiln or the secondary combustion chamber that follows the rotary kiln. An ash handling system at the discharge of the kiln below the vertical secondary combustion chamber processes incinerator ash and slag. Flue gases are drawn by an induced draft (ID) fan through the combustion system and air pollution control equipment train that includes a venturi quench, subcooler, M1 module (Venturi scrubbers), and a wet electrostatic precipitator (WESP), and are discharged through a stack. S4.1 WASTE RECEIVING AND HANDLING S4.1.1 Containerized Materials Receiving, Storage, and Handling Containerized materials are shipped to the incineration facility by tractor trailer. Containers are primarily 55 gallon steel drums. However, wastes are also received in other types of containers, including various sizes of steel drums, totes, plastic and fiber drums, pails, boxes, and portable tanks. The types of containerized wastes that may be received include solids, pumpable sludges, organic and aqueous liquids, and wastes gases. S -1 3M SectionS4 12/18/2009 For processing, containers of liquid are typically transferred to the pump room in Building 47, the sludge processing room in Building 145 or the direct burn room in Building 145. From the pump room in Building 47, pumpable materials are transferred directly to the kiln, to the tank farm, or the 10,000 - gallon decant tank. In the sludge processing room in Building 145, containers are emptied into a sludge hopper that drains into a 2,150 gallon batch tank. The direct burn room in Building 145 is designed for transferring the contents of a container directly to a waste lance. Containerized liquids may also be transferred directly to a waste lance through the direct burn line originating at Building 77. Containers of solids are staged and prepared for processing on the pak feeder or Komar. The drum proceeds to a series of conveyors that ultimately deliver its contents to the kilneither through the drum feed chute or the Komar processor drum feeder. Palletized materials are transferred by a lift and pallet conveyor to the Komar processor pallet feed chamber. S4.1.3 Bulk Liquids Receiving, Storage, and Handling When shipments of bulk liquid waste are received at the facility, liquid wastes are pumped into an appropriate tank at the tank farm. Wastes from waste solvent tanks can be blended by pumping materials to other tanks used to feed the kiln. Bulk liquids can also be transferred from Building 77 directly to a waste lance via the direct burn line. S4.1.4 Bulk Solids Receiving, Storage, and Handling Bulk solids, such as soils and debris, are handled as special projects requiring MPCA approval before unloading to the containment building (Building 181). Bulk material would be delivered by dump truck or roll -off box, unloaded inside the containment building, and repackaged for processing in the kiln as containerized solids. S4.2 KOMAR PROCESSOR The Komar processor shreds multiple containers of waste and extrudes them into the side of the kiln feed chute. The process starts by filling a drop chamber with either palletized containers through the pallet feed chamber or individual drums through a drum dumper in the drum feed chamber. Both feed chambers are equipped with air locks. When the drop chamber is charged, a pair of large opposing tapered screws break up, shred, and mix the material. After this process is completed, hydraulic doors in the bottom of the drop chamber open, and the material falls into the base section. The base section has one large tapered screw auger that pushes the material into the injection screw, a smaller tapered auger. The injection screw discharges material through a rotary isolation valve and feed tube into the kiln. The isolation doors between the drop chamber and the base section allow a batch of material to be processed in the drop chamber while the previous batch is fed to the kiln from the base chamber. The drum feed S -2 3M SectionS4 12/18/2009 chamber, pallet feed chamber, and drop chamber are nitrogen purged and fire protected by a fixed CO2 system. The top of the drop chamber has rupture discs to protect the unit from overpressure. The palletized and drummed wastes going to the drop chamber are weighed on the first floor and then brought to the second floor by either the pallet lift or the individual drum lift. Komar waste feed preparation is a batch process that takes place in the drop chamber. Waste feed to the kiln from the feed chamber is a continuous process. The distributed control system (DCS) uses the weight and waste stream profile constituents of the individual IDs fed into the drop chamber to calculate the total weight and weight of monitored constituents for the batch being processed. When the processing of a batch in the drop chamber has been completed and the previous batch in the feed chamber has been emptied, the operator (PO1) initiates a new feed cycle. The drop chamber exit doors open, moving the new batch to the feed chamber, and the cycle timer for the new batch begins. The DCS incrementally disposes of the total and constituent masses for the batch over the cycle time. If waste feed is halted during a cycle, the cycle timer (and calculated mass and constituent mass feeds) is stopped until waste feed is resumed. A new batch dropped into the feed chamber is not cycled until the cycle timer for the batch currently in the feed chamber has expired. S4.3 ASH HANDLING SYSTEM The major components of the ash handling system include: • Ash quench conveyor • Ash collection and dewatering area Ash and residual solids disengage from the flue gas stream in the lower portion of the secondary combustion chamber and drop on to the loading end of the ash quench conveyor. The ash conveyor is a steel belt type conveyor with its loading end submerged in water to cool the residue and provide an air seal. The ash conveyor moves ash and residual solids upward from the ash quench up a de- watering incline to the ash collection and dewatering area, where they fall from the end of the conveyor into an ash - handling trailer. The ash - handling trailer is used to transfer ash and residual solids to the containment building (Building 181). S4.4 IWTS System The Incinerator Waste Tracking System (IWTS) is a comprehensive database and extensive set of software programs used at the facility. IWTS provides support for shipping and receiving, inventory management, compliance management and reporting, waste processing and S -3 3M SectionS4 12/18/2009 administrative functions. This is accomplished by highly integrated interfaces to the Waste Stream Profile (WSP) System, process control systems such as the Foxboro and Allen - Bradley systems, and the 3M billing systems. S -4 3M Section S5 1/17/2012 SECTION S5 DECONTAMINATION AREA S5.1 INTRODUCTION A structure is provided for decontaminating equipment prior to shipping the equipment off site for repair, recycling or disposal. This area may also be used for decontamination and rinsing required as part of an approved closure activity as described in Section L.5.2 of this application. This structure was originally designed, and is also used as a containment structure when unloading shipments of sulfuric acid solution into a sulfuric acid storage tank. Shipments of sulfuric acid are normally received less than five times per year. Decontamination activities are not conducted whenever a shipment of sulfuric acid is being unloaded. S5.2 DECONTAMINATION AREA OPERATION Decontamination activities include, but are not limited to pressure washing, sand or grit blasting, scraping, and rinsing. If there is a possibility of overspray or for material to become wind -borne from decontamination activities, a temporary screen or enclosure will be erected on the structure to contain the materials. A sump is located at the low end of the structure for collection of liquids. All liquids generated from decontamination activities will be removed from the sump daily and transferred into the Incinerator wastewater treatment system. Any equipment or material placed in the decontamination area, or generated from decontamination activities, will be removed from the decontamination area within 24 hours, unless otherwise allowed under Minnesota rules. If an extension to the 24 -hour time limit is needed, a request will be submitted to the MPCA stating the reason for the request and the time extension that is being requested. S5.3 DECONTAMINATION AREA ENGINEERING DESCRIPTION The location of the decontamination area is shown in the Appendix, Volume 2, Tab A of this application, on drawing number CHEM- 888 -C -142. The design of the decontamination structure is provided on drawing numbers CHEM- 888 -S -012 and CHEM- 888- S -902A. The structure is coated with a protective coating such as TK -2110 Bridge Deck & Crack Sealer, or equivalent. This coating is inspected annually and reapplied as needed. The volume of liquid that can be contained in the decontamination structure is 5,040 gallons. The structural drawings and technical data sheet for the protective coating are included in the Appendix, Volume 3, Tab S4 of this application. S -5 3M Section T 12/18/09 SECTION T SUBPARTS AA, BB AND CC REQUIREMENTS T.1 SUBPART AA REQUIREMENTS The following information is provided in accordance with 40 CFR 270.24, Specific Part B information requirements for process vents. This section requires certain information for facilities that have process vents that are subject to subpart AA of part 264. Subpart AA applies to process vents associated with distillation, fractionation, thin -film evaporation, solvent extraction, or air or steam stripping operations that manage hazardous wastes with organic concentrations of at least 10 ppmw. None of these operations are used to manage hazardous wastes at this site. Subpart AA also applies to closed -vent systems and control devices. Tank 1 is equipped with a flare for emission control in accordance with Subpart CC. By reference, the flare is designed and operated in accordance with Subpart AA, specifically the requirements contained in 40 CFR 264.1033. T.2 SUBPART BB REQUIREMENTS The following information is provided in accordance with 40 CFR 270.25, Specific Part B information requirements for equipment. This section requires certain information for facilities that have equipment that are subject to subpart BB of part 264. The 3M Corporate Incinerator does utilize equipment to which these requirements would be applicable. However, subpart BB states in 40 CFR 264.1064 (m) that "The owner or operator of a facility with equipment that is subject to this subpart and to regulations at 40 CFR part 60, part 61, or part 63 may elect to determine compliance with this subpart either by documentation pursuant to 264.1064 of this subpart, or by documentation of compliance with the regulations at 40 CFR part 60, part 61, or part 63 pursuant to the relevant provisions of the regulations at 40 CFR part 60, part 61, or part 63. The 3M Cottage Grove Corporate Incinerator complies with part 63 subpart DD "National Emission Standards for Hazardous Air Pollutants from Off -Site Waste and Recovery Operations," meeting the following criteria: • The site is a major source of hazardous air pollutant emissions (40 CFR 63.680(a)(1)), and; T -1 3M Section T 12/18/09 • The site receives off -site material and the operation is regulated as a hazardous waste treatment, storage, and disposal facility (40 CFR 63.680(a)(2)(i)). However, since the requirements of these two subparts, 264 BB and 63 DD, are virtually identical, this section of the permit renewal application will reference the requirements as stated is subpart BB. The 3M Corporate Incinerator utilizes a number of piping systems to transfer liquid organic wastes into and between storage tanks and the rotary kiln. A summary of the equipment affected by these regulations is maintained in the facility's Subpart BB Monitoring Plan. Although the types of waste streams processed at the Incinerator vary in composition and properties, all of the equipment is regularly exposed to wastes that both contain greater than 10% VOC content, and meet the definition for "light liquid." Therefore, all of the listed equipment is maintained in compliance with Subpart BB. Equipment Summary Specific equipment that is being monitored as a part of this program is listed in the table Subpart BB Compliance Program, on file at the facility. The following information is included for each monitoring point: 1) Unique equipment I.D. number Each piece of equipment has been tagged with a unique identification number. Exemptions are discussed under Item 5). 2) Type of equipment This identifies the specific piece of equipment (e.g., valve or flange), as well as the type (check valve, ball valve, etc.). 3) Site Location This provides a general description of the equipment location to assist field personnel in conducting monitoring. 4) Method of Compliance This lists inspection frequency and method(s) of monitoring. 5) Exempt Equipment Certain pieces of equipment are exempt from monitoring requirements. The reason for an exemption is listed in this column (e.g., equipment no longer in use, or equipment that is wrapped in insulation and not accessible for monitoring). T -2 3M Section T 12/18/09 Specific test results are also kept on file at the facility. Other information required in 270.25(a) include the percent by weight of total organics in the waste stream, and the hazardous waste state at the equipment. Although the waste streams vary in concentration and properties, VOC concentration can range up to 100 %, and all of the wastes in the regulated equipment are liquids. Monitoring Conducted Equipment covered under this regulation is monitored for leaks as discussed below. All monitoring data is maintained on file at the facility. 1) Valves Each valve is monitored in accordance with Reference Method 21. A leak is defined as an instrument reading of 10,000 ppm or greater. If a leak is detected, an attempt is made to repair the leak within five days. All repairs are made within 15 days or the equipment is taken out of service. 3M has notified the Minnesota Pollution Control Agency that it has chosen to comply with the Alternative Standard for Valves, mandating that no more than 2% of the valves may leak. Monitoring in accordance with this alternative standard is conducted annually. 2) Pumps 3M uses several methods to comply with the leak detection requirements for pumps. Pumps are visually inspected weekly for leaks. They are also monitored monthly using Reference Method 21 unless the pump is equipped with a dual mechanical seal system that includes a barrier system meeting the requirements of 264.1052(d) or is designated as having "no detectable emissions" as described under 264.1052(e). A leak is defined as an instrument reading of 10,000 ppm or greater. If a leak is detected, an attempt is made to repair leak within five days. All repairs are made within 15 days or the equipment is taken out of service. 3) Flanges Flanges are monitored daily for visual, olfactory, or audible signs of leakage. Any flange suspected of leaking is monitored with a hydrocarbon analyzer within five days. If a leak is detected, an attempt is made to repair the leak within five days. A leak is defined as an T -3 3M Section T 12/18/09 instrument reading of 10,000 ppm or greater. All repairs are made within 15 days or the equipment is taken out of service. Monitorinq Procedures Equipment monitoring is conducted in accordance with Method 21 procedures. When a piece of equipment is monitored, the analyzer inlet is placed at the surface of the leak interface where leakage could occur. The probe is then moved along the interface while the instrument readout is observed. If an increased meter reading is observed, the probe is slowly moved along the interface where leakage is indicated until the maximum meter reading is obtained. The probe inlet is left at this maximum reading location for approximately twice the instrument's response time. The maximum reading is recorded as the screening value. Care is taken to avoid getting the probe tip dirty. A piece of Teflon tubing may be put on the end of the probe to extend its reach and keep the probe from becoming dirty. The.tubing must be cleaned periodically to insure that the analyzer has the proper inlet flow rate. This general procedure can be used to test equipment such as valves, flanges, pumps and compressors, pressure relief devices, and other potential sources of VOC leakage. Leaking Equipment If a leak is discovered in a valve, pump, flange, or fitting, it is documented on a Leak Inspection Form. When the leak is found, the log of Leaking Equipment is filled out and the following identification protocol is implemented: • A weatherproof, readily visible identification tag marked with the leaking equipment I.D. number will be attached to the leaking equipment. • The identification tag on the pump or flange may be removed after the leak has been repaired. • The identification tag on a leaking valve may be removed only after the valve has been monitored for two successive months without detecting a leak. Notifications The Agency was notified when equipment monitoring began. MPCA was also notified that 3M has opted to comply with the Alternative Standard for Valves. The Summary of Monitored Equipment is maintained at the facility in the facility's Subpart BB Monitoring Plan, and is revised on an as- needed basis. T -4 3M Section T 12/18/09 T.3 SUBPART CC REQUIREMENTS The following information is provided in accordance with 40 CFR 270.27, Specific Part B information requirements for air emission controls for tanks, surface impoundments, and containers. This section requires certain information for facilities that have tanks, surface impoundments, and /or containers that are subject to subpart CC of part 264. Subpart CC applies to facilities that manage hazardous wastes with volatile organic concentrations of at least 500 ppmw in tanks, surface impoundments, and /or containers. The 3M Cottage Grove Corporate Incinerator does manage wastes in tanks and containers. The site does not manage wastes in surface impoundments, and therefore the surface impoundment requirements of subpart CC are not applicable. In subpart CC, 264.1080(b)(7) states that CC requirements are not applicable to "...a hazardous waste management unit that the owner or operator certifies is equipped with and operating air emission controls in accordance with the requirements of an applicable Clean Air Act regulation codified under 40 CFR part 60, 61 or 63." The 3M Cottage Grove Corporate Incinerator does comply with part 63 subpart DD "National Emission Standards for Hazardous Air Pollutants from Off -Site Waste and Recovery Operations," meeting the following criteria: • The site is a major source of hazardous air pollutant emissions (40 CFR 63.680(a)(1)), and • The site receives off -site material and the operation is regulated as a hazardous waste treatment, storage, and disposal facility (40 CFR 63.680(a)(2)(i)). In accordance with 40 CFR 264.1080(a)(7), 3M complies with 40 CFR 63 Subpart DD rather than 40 CFR 264 Subpart CC. However, since the requirements of these subparts, 264 CC and 63 DD, are virtually identical, this section of the permit renewal application will reference the requirements as stated is subpart CC. The requirements of 40 CFR 270.27, Specific Part B information requirements for air emission controls for tanks, surface impoundments, and containers, are addressed as follows: (1) Documentation of floating roof covers — All hazardous waste tanks at this site are fixed roof atmospheric tanks. Requirements for floating roof covers are not applicable. (2) Identification of each container area subject to the requirements of subpart CC, and certification that the requirements of this subpart are met - Container storage areas, including T -5 3M Section T 12/18/09 location, capacity, and secondary containment volume, are described in Section S1 of this permit application. 3M certifies by submittal of this permit application that the 3M Corporate Incinerator meets the requirements of subpart CC. (3) Documentation for each enclosure used to control air pollutant emissions — Enclosures are not used for air pollution control of regulated units at this site, and therefore these requirements are not applicable. (4) Documentation for each floating membrane cover on a surface impoundment — Surface impoundments are not used to manage hazardous waste at this site, and therefore these requirements are not applicable. (5) Documentation for each closed -vent system and control device — This requirement is applicable only to Tank 1 at this facility. Based on tank capacity and materials stored, this tank complies with Tank Level 2 requirements as defined in Subpart CC. Compliance is achieved by means of a flare, which is designed and operated in accordance with Subpart AA. (6) An emission monitoring plan, and control device monitoring methods — None of the subpart CC control options that would require monitoring are used for air pollution control of regulated units at this site, and therefore these requirements are not applicable. T -6 VOLUME 2, APPENDIX TABLE OF CONTENTS Tab Title A DRAWING NO. CHEM- 888 -C -142: WASTE MANAGEMENT AREAS O LIABILITY COVERAGE AND CLOSURE LETTERS S1 a SUMMARY OF SECONDARY CONTAINMENT VOLUMES FOR BUILDINGS 47, 60, 77,136 AND 145 S1b DRAWING NO. CHEM- 145 -A -121 BLDG 145 LOWER LEVEL SEC. CONTAINMENT S1c DRAWING NO. CHEM -145 -A -122 BLDG 145 MAIN FLOOR SEC. CONTAINMENT Std DRAWING NO. CHEM- 145 -A -123 BLDG 145 UPPER LEVEL SEC. CONTAINMENT Ste SUMMARY OF SECONDARY CONTAINMENT VOLUMES FOR CONTAINMENT TRAILERS AND STORAGE LOTS S1f DRAWING NO. CHEM 047 -A -702 BLDG 47 MISCELLANEOUS DETAILS S1g DRAWING NO. CHEM -60 -A -200 BLDG 60 BASEMENT AND MAIN FLOOR PLANS S1 h DRAWING NO. CHEM- 077 -S -010 BLDG 77 FLOOR AND DOCK PLANS S1i DRAWING NO. CHEM- 136 -S -919 BLDG 136 TANKER UNLOADING DETAILS S1j DRAWING NO. CHEM- 888- C -664J LOT C PARTIAL SITE PLAN S1k DRAWING NO. CHEM- 888- C -664K LOT MISCELLANEOUS DETAILS, INCLUDING SUMP VOLUME 3, APPENDIX TABLE OF CONTENTS Tab Title S2a CALCULATION OF SECONDARY CONTAINMENT VOLUMES FOR STORAGE TANKS S2b FIGURE S2 -5. DRAWING NO. CHEM- 145- M -903C SLUDGE TANKS P & ID S2c DRAWING NO. CHEM- 060 -S -902 BLDG 60 DIKE AND CATWALK Std DRAWING NO. CHEM- 888- C -664E TANK FARM PARTIAL SITE PLAN AND DETAILS S2e DRAWING NO. CHEM- 888- C -630F UNDERGROUND CONTAINMENT TANK S2f DRAWING NO. T -6235 VERTICAL SUMP, CONTAINMENT TANK S2g DRAWING NO. CHEM- 136 -M -910 TANK #1 P & ID S2h DRAWING NO. CHEM 047 -M -930 TANK FARM FLOW DIAGRAM S2i DRAWING NO. CHEM- 136 -M -901 TANK FARM P & ID S2j DRAWING NO. CHEM -136 -M -902 TANK FARM P & ID S2k DRAWING NO. CHEM- 136 -M -903 TANK FARM P & ID S21 DRAWING NO. CHEM- 136 -M -904 TANK FARM P & ID S2m DRAWING NO. CHEM- 136 -M -905 TANK FARM P & ID S2n DRAWING NO. CHEM- 136 -M -906 TANK FARM P & ID S2o DRAWING NO. CHEM- 136 -M -907 TANK FARM P & ID S2p DRAWING NO. CHEM- 136 -M -908 TANK FARM P & ID S2q DRAWING NO. CHEM- 136 -M -909 TANK FARM P & ID S2r DRAWING NO. CHEM- 047 -M -933 BLEND TANK AREA P & ID S2s DRAWING NO. CHEM- 888 -C -6081 NEW TANK FARM LAYOUT S2t DRAWING NO. CHEM- 888- C -608K NEW TANK FARM DETAILS S2u DRAWING NO. CHEM- 888 -M -931 TANK #1 PIPING DETAILS S2v DRAWING NO. CHEM- 888- C -608E TANK #1 LEAK DETECTION DETAILS S2w DRAWING NO. CHEM- 888- C -608F TANK #1 LEAK DETECTION SUMP DETAILS S2x CERTIFICATION OF TANK #1 S2y CERTIFICATION OF TANK # 10 S3a DRAWING NO. CHEM- 181 -A -800 BULK SOLIDS BUILDING S3b CERTIFICATION OF BLDG 181 VOLUME 3, APPENDIX TABLE OF CONTENTS Tab Title S2 CALCULATION OF SECONDARY CONTAINMENT VOLUMES FOR STORAGE TANKS FIGURE S2 -5. DRAWING NO. CHEM- 145- M -903C SLUDGE TANKS P & ID DRAWING NO. CHEM- 060 -S -902 BLDG 60 DIKE AND CATWALK DRAWING NO. CHEM- 888- C -664E TANK FARM PARTIAL SITE PLAN AND DETAILS DRAWING NO. CHEM- 888- C -630F UNDERGROUND CONTAINMENT TANK DRAWING NO. T -6235 VERTICAL SUMP CONTAINMENT TANK DRAWING NO. CHEM- 047 -M -929 TANK #1 P & ID DRAWING NO. CHEM- 047 -M -930 TANK FARM FLOW DIAGRAM DRAWING NO. CHEM- 047 -M -931 TANK FARM P & ID DRAWING NO. CHEM- 047 -M -932 BLEND TANK AREA (DECANT TANK) P & ID DRAWING NO. CHEM- 047 -M -933 BLEND TANK AREA P & ID DRAWING NO. CHEM- 888 -C -6081 NEW TANK FARM LAYOUT DRAWING NO. CHEM- 888- C -608K NEW TANK FARM DETAILS DRAWING NO. CHEM- 888 -M -931 TANK #1 PIPING DETAILS DRAWING NO. CHEM- 888- C -608E TANK #1 LEAK DETECTION DETAILS DRAWING NO. CHEM- 888- C -608F TANK #1 LEAK DETECTION SUMP DETAILS CERTIFICATION OF TANK #1 CERTIFICATION OF TANK #10 S3 DRAWING NO. CHEM- 181 -A -800 BULK SOLIDS BUILDING CERTIFICATION OF BLDG 181 S5a DRAWING NO. CHEM- 888 -S -012 COOLING TOWER FOUNDATION PLAN, INCINERATOR AREA S5b DRAWING NO. CHEM- 888- S -902A COOLING TOWER FOUNDATION SECTIONS & DETAILS, INCINERATOR AREA S5c TECHNICAL DATA SHEET FOR TK -2110 BRIDGE DECK & CRACK SEALER - t "'M T �w r..- YwIS4 , ro�� _ J''On •T -' _ n 41mm F _ _______ __ _ _ __ °� § jl Ily PL CONCR SLAB OVER COLD II gg � 4r. � i _ � ,.r 4g g § §_ is =Za iL wl - ------- fir PLAN OF CONCRETE SLAB g� m FOR M.C.C. BUILDING § r, COOLING TOWER FOUNDATION AND UNLOAD AREA PLAN IZZ Id I O .7C� r°O°s° osxmaa iw 1�.. i.T"v�v w COOLING TOWER NCI NOATION PLAN _� �_�_ INCINERATOR MEA .-® 3M Internal Correspondence To: M. Hirano — EHS Opns — 224-5W- R.D. Edmonds Cottage Grove - 116 -1 01/064 G.D. Garner— Cottage Grove 01/064 V,J. Batroot — Cottage Grove - 116 -1— 01/064 JM Christensen — Cottage Grove - 114 -1 01/064 From: B.A. Kwiatkowski (737 -3478) — EHS Opns — 224 -2E -55 Subject: Annual Financial Assurance Report - COCI Date: March 30, 2009 Please find enclosed a copy of the 2009 (for year end 2008) financial assurance documentation for the Cottage Grove Corporate Incinerator. As noted, copies were sent to the appropriate federal and/or state agencies. Contact me if you have any questions. BAK Enclosure c* T. G. Ashenmacher =-- 01 /064 R.A. Paschke — 224 -2E -55 *Less Enclosure FILE: CHEM -INC P C -� 11-1 3M General Offices March 30, 2009 qW Regional Administrator EPA, Region V 77 West Jackson Boulevard Chicago, IL 60604 3M Center St. Paul, MN - )5144 -1000 651 733 1 l I0 Subject: Financial Assurance for Closure of Hazardous Waste Storage and Treatment Facilities Gentlemen: The attached statement from PricewaterhouseCoopers LLF, Certified Public Accountants, and the letter from Patrick D. Campbell, Senior Vice President, Finance and Chief Financial Officer, certify that 3M meets the Financial Test and Corporate Guarantee for Closure as required by 40 CFR Parts 264 and 265, Subpart H, Section 265.143, Paragraph (e). 3M is the owner of plant located at 10746 Innovation Road Cottage Grove, MN P.O. Box 33131 St. Paul, MN 55133 EPA ID No. MND 006172969 that has final status as RCRA. hazardous waste storage facilities. Similar letters with attachments have been sent to the'Manager, Major Waters and Land Section of the Minnesota Pollution Control Agency to comply with the Financial Test and Corporate Guarantee for Closure. This copy is sent to your attention for information only. Please contact me at (651) 737 -3634 if there are any questions .. information. Please direct any correspondence regarding this undersigned at the address listed in the letterhead, Sincerely, Robert A. Paschke, P.E., D.E.E. Manager, Corporate Environmental Programs or need for additional matter to the Enclosures 3M General offices 3M Centcr St. Paul, MN 55[44 -1000 651 733 1110 March 30, 2009 Mr. Tom Townsend Minnesota Pollution Control Agency Industrial Water & Land Sectors Unit Majors and Remediation Division 520 Lafayette Road St. Paul, MN 55155 -4194 Subject: Financial Assurance for Closure of Hazardous Waste Storage and Treatment Facilities Dear Mr. Townsend, Attached for your information is a copy of the letter from Patrick D. Campbell, Senior Vice President, Finance and Chief Financial Officer, and the statement from PricewaterhouseCoopers LLP, Certified Public Accountants, certify that 3M meets the Financial Test and Corporate Guarantee for Closure as required by 40 CFR Parts 264 and 265, Subpart H, Section 265.143, Paragraph (e). Per your instructions, the original signed copy of this document was sent to Ms. Johnna Benke. Please contact me at (651) 737 -3634 if there are any Questions or need for additional information. Please direct any correspondence regarding this matter to the undersigned at the address listed in the letterhead. Sincerely, Robert A. Paschke, P.E., D.E.E. Manager, Corporate Environmental Programs Enclosures CC: M. Hirano EHS Opns - 224 -5W -03 R.D. Edmonds Cottage Grove - 116 -1— 01/064 G.D. Garner — Cottage Grove 01/064 V.J. Batroot -- Cottage Grove 116 -1 - 01/064 J.M Christensen - Cottage Grove - 114 -1 — 01/064 /bak 3hi General Offices 3M Center St. Paul, MN 55144 -1000 651 733 1110 March 30, 2009 vim Ms. Jrohnna Ben�ke Minnesota Pollution Control Agency Manager, Majors Water & Land Section 520 Lafayette Road St Paul, MN 55155 -4194 Subject: Financial Assurance for Closure of Hazardous Waste Storage and Treatment Facilities Dear Ms. Benke, The attached letter from Patrick D. Campbell, Senior'rVice President, Finance and Chief Financial Officer, and the statement from PricewaterhouseCoopers LLP, Certified Public Accountants, certify that 3M meets the Financial Test and Corporate Guarantee for Closure as required by 40 CFR Parts 264 and 265, Subpart H, Section 265.143, Paragraph (e). Also enclosed for your information and records is a combined SEC Form 10K and 2008 3M Annual Report. 3M is the owner of plant located at: 10746 Innovation Road Cottage Grove, MN P.O. Box 33131 St. Paul, MN 55133 EPA ID No. MND 006172969 that has final status as RCRA hazardous waste storage facilities Similar letters with attachments have been sent to the Regional Administrator for informational purposes. Please contact me at (651) 737 -3634 if there are any questions or need for additional information. Please direct any correspondence regarding this matter to the undersigned at the address listed in the letterhead. Sincerely, Robert A. Paschke, P.E., D.E.E. Manager, Corporate Environmental Programs Enclosures 3M General Offices 3M Ccnter St. NILIl, MN 55 144- 1000 (01 733 1110 March 30, 2009 D Ms. Johnna Benke Minnesota Pollution Control Agency Manager, Majors Water & Land Section 520 Lafayette Road St; Paul, MN 55155 -4194 Subject: Financial Assurance for Closure of Hazardous, Waste Storage and Treatment Facilities Dear Ms. Benke I am the Chief Financial Officer of 3M Company, 3M Center, St. Paul, Minnesota 55144. This letter is in support of the use of the financial test to demonstrate financial responsibility for liability coverage and closure and/or post-closure care as specified in Subpart 'H of 40 CFR Parts 2614 and 265. The firm identified above is the owner or operator of the following facilities for which liability coverage for sudden accidental occurrences is being demonstrated through the financial test specified in Subpart T i of 40 CFR Parts 264 and 265. Facility Location 'EPA LD. Number 3M Company MND006172969 10746 Innovation Road Cottage Grove, MN P.O. Box 33131 St. Paul, MN 55133 3M Company MOD054950670 5400 Route B P.O. Box 1228 Columbia, MO 65205 3M Company CAD981449739 8357 Canoga Ave. Canoga Park, CA 91304 3M Company ALD004023164 State Docks Rd. Decatur, AL 35609 Minnesota Pollution Control Agency Page 2 March 30, 2009 The firm identified above guarantees, through the guarantee specified in Subpart kI of 40 CFR Parts 264 and 265, liability coverage for sudden accidental occurrences at the following facilities owned or operated by the following: None 1. The firm identified above owns or operates the fallowing facilities for which financial assurance for closure or post - closure care or liability coverage is demonstrated through the financial test specified In Subpart 11 of 40 CFR Parts 264 and 265. The current closure and/or post - closure cost estimates covered by the test are shown for each facility: None 2. The firm identified above guarantees, through the guarantee specified in Subpart H of 40 CFR Parts 264 and 265, the closure and post - closure care or liability of the following facilities owned or operated by the guaranteed party. The current cost estimates for closure or post- closure care so guaranteed are shown for each facility: None 3. in states where EPA is not administering the financial requirements of Subpart H of 40 CFR Parts 264 and 265, this Firm is demonstrating financial assurance for the closure or post - closure care of the following facilities through the use of a test equivalent or substantially equivalent to the financial test specified in Subpart H of 40 CFR Parts 264 and 265. The current closure or post - closure cost estimates covered by such a test are shown for each facility: Facility. Location EPA, I.D. Number Closure Post- Closure Amount Amount 3M Company MND006172969 $13,702,320 -- 10746 Innovation Road Cottage Grove, MN P.O. Box 33131 St. Paul, MN 5513' Company - Closed $5,831,204 3149 Copley Road Copley, Ohio 44321 3M Company MOD054950670 Closed $1,164,452 5400 Route B ($27,154.98/yr. for 22 yrs) P.O. Box 1228 ($19,553.19/yr. for 29 yrs) Columbia, MO 65205 3M Company CAD981449739 $106,251 -- 8357 Canoga Ave. Canoga Park, CA 91304 3M Company - ALD004023164 $1,952,576 $25,286,804 State Docks Rd. ($760,776.80/yr. for 30 yrs) Decatur, AL 35609 ($82,116.68/yr. far 30 yrs) Minnesota Pollution Control Agency Page 3 March 34, 2009 4. The firm identified above owns or operates the following hazardous waste management facilities for which financial assurance for closure or, if a disposal facility, post- closure care, is not demonstrated either to EPA or a state through the financial test or any other financial assurance mechanisms specified in Subpart H of 40 CFR Parts 264 and 265 or equivalent or substantially equivalent state mechanisms. The current closure and/or post - closure cost estimates not covered by such financial assurance are shown for each facility: None 5. This firm is the owner or operator or guarantor of the following UIC facilities for which financial assurance for plugging and abandonment is required under 40 CFR Part 144 and is assured through a financial test. The current closure cost estimates as required by 40 CFR 144.62 are shown for each facility; None This firm is required to file a Form 10 -K with the Securities and Exchange Commission (SEC) for the latest fiscal year. The fiscal year of this firm ends on December 31; The figures for the following items marked with an asterisk are derived from this firm's independently audited year -end financial statements for the latest completed fiscal year, ended December 31, 2008, or from the related accounting records of the firm. Minnesota Pollution Control Agency Page 4 March 30, 2009 ALTERNATIVE II 1. Sum of current closure and post - closure cost estimates (total of all cost estimates listed above).....,—, . ............ $ 48,043,608 2. Amount of annual aggregate liability coverage to be demonstrated $ 8,000,000 3. Sums of lines 1 and 2 $ 56,043,608 4. Current bond rating of most recent issuance and name of rating service.. ... . .AA.- with stable outlook; Standard & Poors Aal with negative outlook; Moody's 5. Date of issuance of bond .... October 27, 2008 6. Date of maturity of bond ............................................... November 1, 2011 7. Tangible net worth (if any portion of the closure or post- closure cost estimates is included in "total liabilities" on your financial statements, you may add that ,portion to this line) ...... ... ................ ................. ......... ............ $2.7 Billion* 8. Total assets in the U.S. (required only if less than 90% of assets are located in the U.S.) ........... $12.9 Billion* ... .................. Yes No 9. Is line 7 at least $10 millions X 10. Is lime 7 a least 6 times line 3? X 11. Are at least 90% of assets located in the U.S.? If not, complete line 12 ... ...,..... . ...............•.............. X 12. Is line 8 at least 6 times line 31 .................................... X I hereby certify that the wording of this letter is identical to the wording specified in CFR 264.151 (g) as such regulations were constituted on the date shown immediately below. c?2 LLO Patrick D. Campbell Senior Vice President and Chief Financial Officer March 30, 2009 PREEWATERHOUSECCOPERS � PricewaterhouseCoopers LLP Suite 1400 225 South Sixth Street Minneapolis MN 55402 Telephone 1612) 596 6000 Facsimile (612) 3 Report of Independent Accountants To 3M Company' We have audited i) the consolidated balance sheet of 3M Company (the "Company ") at December 31, 2008 and 2007 and the related consolidated statements of income, of changes in stockholders' equity and comprehensive income, and of cash flows for each of the three years in the period ended December 31, 2008, and ii) the effectiveness of the Company's internal control over financial reporting as of December 31, 2008. The consolidated financial statements referred to above are included in''the Company's Annual Report on Form 10 -K for the year ended December 31, 2008 as filed with the Securities and Exchange_ Commission; and, further, a copy of our report with respect thereto, dated February 10, 2009, is also included therein and attached hereto. , We have performed the procedures enumerated below, which were agreed to by the Company, solely to assist you with respect to the Company's filing with the Minnesota Pollution Control Agency under the reporting requirements for the use of the financial test to demonstrate financial assurance pursuant to the regulations issued under the authority of the Resource Conservation and Recovery Act of 1976, as amended. Management is responsible for compliance with the aforementioned filling requirements. This agreed -upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. We have read the attached letter from Mr. Patrick D. Campbell, Senior Vice President and Chief Financial Officer of the Company, dated March 30, 2009, submitted in accordance with the aforementioned reporting requirements, and performed the following procedures with respect to specified data as set forth on page 4 of Mr. Campbell's letter: S' eci #ied Data`tn Letter Procedures-A` reed U oln and Descri tlon of indin s '- 1. No. 7 - "Tangible Net Worth" We compared the amount per the letter of $2.7 billion with Total Assets, net of Goodwill, Intangible Assets and Total Liabilities, all of which appear in the Company's December 31, 2008 consolidated balance sheet referred to above, and found them to be in agreement therewith, after rounding. ' Tangible net worth as defined in the Code of Federal Regulations (40 CFR, paragraph 264.141 (f)) means, "the tangible assets that remain after deducting liabilities; such assets would not include intangibles such as goodwill and rights to patents or royalties." PRICaVATERHOUSECOOPERS M ;S" ecifietlData in.Letter ,- ;`' " ° Procedures A reed`U qn antl pescri tign:of•.Fntlin "s. 2. No. 8 - "Total Assets in the We compared the amount per the letter of U.S." $12.9 billion with a Company prepared schedule of the United States total assets balance (excluding inter company accounts) and found them to be in agreement, after rounding. Components in the schedule were compared to the Company's accounting records and found to be in agreement therewith. We then compared the Company's total consolidated asset balance on the schedule referred to in the preceding sentence to the Company's December 31, 2008 consolidated balance sheet and found them to be in agreement therewith, after rounding. 3. No. 11 - "Are at Least 90 %0 of We compared the United States total assets balance Assets Located in the U.S. ?" (excluding inter- company accounts) per a'Company prepared schedule to the Company's Total Assets amount appearing in the Company's December 31 2008 consolidated balance sheet and found the total United States assets (excluding inter- company accounts) to be less than 90 % of the Company's Total Assets. This report relates only to the accounts and items specified above and does not extend to the other disclosures in Mr, Campbell's letter dated March 30, 2009, We were not engaged to and did not conduct an examination, the objective of which would be the expression of an opinion on the specified elements, accounts, or items. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. This report is intended solely for the information and use of the Company and is not intended to be and should not be used by anyone other than these specified parties. �J March 30, 2009 Report of independent Registered Public Accounting Firm To the Stockholders and Board of Directors of 3M Company: In our opinion, the consolidated financial statements listed In the accompanying index present fairly, in all material respects, the financial position of 3M Company and its subsidiaries (the "Company ") at December 31, 2008 and 2007, and the results of their operations and their cash flows for each of the three years in the period ended December 31, 2008 in conformity with accounting principles generally accepted in the United States of America.. Also in our opinion, the Company maintained, in all material respects, effective internal control over financial reporting as of December 31, 2008, based on criteria established in Interne! Control integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Company's management is responsible for these financial statements,, for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over financial reporting, included in "Management's Report on Internal Control Over Financial Reporting" in the accompanying index. Our responsibility Is to express opinions on these financial statements and on the Company's internal control over financial reporting based on our integrated audits. We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audits to obtain reasonable assurance about whether the financial statements are free of material misstatement and whether effective internal control over financial reporting was maintained in all material respects. Our audits of the financial statements included examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. Our audit of internal control over financial reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that 'a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audits also included performing such other procedures as we considered necessary in the circumstances. We believe that our audits provide a reasonable basis for our opinions. As discussed in Note 1 to the consolidated financial statements, the Company changed the manner in which it accounts for defined benefit pension and other post- retirement plans in 2006 and the manner in which it accounts for uncertain tax positions in 2007.. A company's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company's internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (iii) provide reasonable a.". urance regarding preventinn or timely detection of unauthorized acquisition, use, or disposition of the company's assets that could_ have a material effect on the financial statements. As described in "Management's Report on Internal Control Over Financial Reporting" in the accompanying index, management has excluded Aearo from its assessment of internal control over financial reporting as of December 31, 2008 because it was acquired by the Company in # purchase business combination during 2008. We have also excluded Aearo from our audit of internal control over financial reporting. Aeara is a wholly -owned subsidiary of the Company whose total assets and total net sales represent less than 10% and less than 2 %, respectively, of the related consolidated financial statement amounts as of and for the year ended December 31, 2008 Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. N, I P � R �_. � PricewaterhouseCoopers LLP Minneapolis, Minnesota February 10, 2009 R� 0 l . .: 2 4i k U� , Z �\ �LLJ :< 0 L . 2 . / pq i 2 ■ f� � - ƒ§ qk ■ ig �£ a S ■C CONTAINMENT .§ E $ \ 7 k .� cc . 0 y 7 B $ � k 4 / � §§ ) ED § /$ LL. . . � � . � | E , � � U . ... J 1-4 � m R� 0 l . .: 2 4i k U� , Z �\ �LLJ :< 0 L . 2 . / pq i 2 ■ f� � - ƒ§ qk ■ ig �£ a S ■C CONTAINMENT q W LLJ p U W Z w L �D Y 4 b c n 4' E I I r` I 0 0 J a D 8 M y ^ 2 2 H H J Z N NN Ll u qq � N w N n N , Q = � 1 J ig w CD Nz N N J O W J 1a7 ; e U Z � a� A da 29 ig N W ae .r YJ Q U Q : N O LL Q Q" ~ f z Lil 4 W Q ZX AU J p q U I k I 3M Civil (Department St. Paul, y1N 551 44 -1000 C4►7.aci� t If • IF r v S-loca ! 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CD _.48`.X S "L� x `�z� � "�1�.� . � , 23 5.. _ ,... .. _ t-1 : ��'_�c ►_ -3 " 'r i X11, Y nz © _ z` x ele x lkc V %L - 6. 13 `i ZSI . 0 x 7 4?i C,Aq GAu -Ot4 �/ %3 / ( Z�� = '1, 4Z$ x Y3 Zr! iZ) 7 OZ -fu V5 ( ,�z� � = is, %3 C Z"Y+ I. x 2 "�1L� = I (o. 4 l �Z` X I' -3•• x rz. ,, /12� Am ist 15 Pwo Gty _ P•oj4CVRFCZS NO SYOWC: 3M Civil Department ca Gro\ /e _ T "; T r. Oih�wn 9 wv. �J 8y St. Paul, AAN 5Sia4 -1Q�J0 ^�L� M I — c 7 ac i♦ e Scrn a Area a- Tr, G a CIO, R .e• ►'vw\� Are9 __ T r,c Co , _ Volw•.e - 94.00 Tre--6, se X ► °3 " x 793` - ion. -•"793' - G`' 23 1 z S 55` -6" 'A 1 x 193 °to 6 - 1 93'- 23 12 `74; 58A F,3 raga 17194 CuY A•o,rC.tfFC_53 too - 3M Civil Oepartment p Gr ove r J - 7, - 1 ncwN r cr ►�2 7 civilian Biaq. Na By cut p St. Paul MN S 61 44- 1 000 4'�LC T: met 7/ Z JQA. C c�c ►� SiAc m - Areas Zr, Gd I ions lull 94 t' l e v�h - __... 9. X K io.5`L} +. � ► 3' w x 4$'L - 7 � S'W x - 3 3, SF x YZ- 94` - 193' - 10 297. 1z5CF Z� �37G d o' L - 7 . Z9 GF Z' c� ? 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I M SPILL CONTAINMENT PLAN n nw lililliql1i Him �� �t� I� I�� . � h �_ L�� � D I� L ► D ��s� ■lid'; ��h - - - �>�_ 0 MINI Siam FORM 11ROMMOR U PI H m Wm� ARCHrrECTURAL WE= LIVIL I VILL CONTAINII. PLAN kw= bw —, =TERkAL =D NG BUILW� e=E�oammv ... r s .,, -- - - ee���ee�� -e��� MATERIAL HANDLING BUILDIN L7iLrairaoGS' ee���eee�ee��e�se��� Ir�Yi� e LOT B SCALE 30' DR. TBG/RR0 PLAN INCINERATOR AREA OAT 11/1/97 COTTAGE GROVE '888 MINNESOTA FILENAME 142E.DWG NU MBER OF SPACES 2 SP ACES (10' x 50') ____j / 4 HYD 11/1/97 GLG I(TBG/RAK)ORIGINAL ISSUE 0-111-1-11 3M COPYRIGHT ig _17 . 11.11 FACILITIES ENGINEERING DEPARTMENT/3M t., tHis D=U--NT ts TK Comm,-HMO di� m PW)MTY Of THE 311 COOPAW MO MAY *OT K REPRODUCED WITHOUT BOG. 42 11 ;&MMN PERUtSWOM OR USED 11 ONER THM �M AWMQRjZtD 900 BUSH AVENUE 3M PURPOSES. Plo. Box 33331 ST. PAUL, MN 55133 P03 E 0 MA _ r® u SCALE OT M 80 L ' DR. PLAN T6G/RR0 INCINERATOR AREA DATE COTTAGE - GROVE 888 MINNESOTA FILEN4ME 142F.DWG NUMBER OF SPACES 96 SPACES (10' x 50') A ■ � P, Apr . IM A 1 1/l/97 GLG (TE3G/RAK)0RIGINAL ISSUE (D 3M COPYRicHr 19 FACILITIES ENGINEERING DEPARTMENT/3M. NT 13 THE COWMGMIED NOT THe 31, WITHOUT Be REPRODUCCO BLDG. 42 5+4 WEfTPEN KRUISSION OR USED i0q OTHER THAN JW _Nffl40MZE0 900 BUSH AVENUE P.O. Box 33331 ST. PAUL, MN 55133 �� 3 ° r L o L < Lai LJ :LI / = N �u� \ ��� . . . LLJ ? / 2 k� C h k_/ S 3k «/ 9L / w 2= u i �� f 9 # a \ »: LLJ :d } _ .m m Z $ 2 \� R . . W k .�� ( ?. : Ui 2 } ! � . w - : 0 ) m |_ � f� L omzi, b K W61qlF � C e F ` �����I� �� �`� °� X11 �►� 3i ���� s alt OFF. . tQA kp- 1 0 , VV\ VA 5y- a I (o I vl V\ (�oL� _)- l I �I I� _I i It5 , 0, 'O n 0� m C Cu O Ot 't Oc0oNr.4 N to c0 tO h 0 CD rn O M N r �V M# t1! 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D1 M f• th O1 ID cq h CO r CD r C O N '7 (D r tD (O C) co Ch r r 7 m CO LO N h« o 0 Cl) 09 M O '?. a CD :G ED Ci 4;6 h h N 0 w N to v ? v m M N N N r r O r M Q Lq CG w � N — q r m ` d h M N w 0 a N to h O OJ CD m r M to (M N v co T cr to td► CA 10 h h CD W O N 1) C N O �` .�. C ® tf1 O O N M O LO 00 O N 1* W M tO h O N d' LO Cp N W O v- y LL ` Qf O .- N M Ln IS n C] N d CO O L'0 LA n O N �4 lA CO h CO O r Q A'.rr r N N 04 NN M!MMM a s LO r r Containment Trailer Design Relationship Between Front -to -Back and Side -to SN (16 inch containment pan - 40 and 45 foot long t e ''Slopes ailers) ........................ . Maximum Allowable Side :Slope Front -to -Back Trailer Slo es 45 It trailer (degrees) 40 ft, trailer f _ de rees ( degrees) O:sS 0.43 0.08 0.31 1.00 0.45 0.2 0.46 1. • 1 0 0.50 0.5 0.75 1.25 0.56 0.95 1.21 1.33 _ 0.60. 1.19 1.47 1.50 0.68 1.74 2.03 1.55 0.70 1.9 2:2 1 -,76 0.80 2.67 2.99 2.00 0.90 3.44 3.77 2.22 1.00 4.22 1 _ 4.58 2.44 1.10 5.03 5.4 2.66 1.20 5.85 6.24 2.89 1.30 6,73 7,13 3,11 1.40 6.75 7.17 3.33 _ 1.50 6.44 6.87. 3,55 1.60. 6.13 6.58 3.77 1.70 5.84 6.3 4.00 1.80 5.54 6.02 4.22 1.90' 5.26 5.75 4.44 2.00 4.99 5.49 5.55 2.50 3,71 4,2$ 6,66 3.00 2.56 3:18 7.77 3.50 1.5 2,17 8.88 4.00 0.51 1.23 10.00 4.50_ -0.42 0:34 Containment Trailer Design Relationship Between Front -to -Back and Side -to -Side Slopes (16 inch containment pan - 40 and 45 foot tong trailers) UMVImf1Yn d1lnu16' kle QA- QL...'i. Front -to -Sack Trailer :Slopes 45 ft. trailer (degrees) 40` ft. trailer de gees ( degrees) 0:95> 0.43 0.08 0.31 1.00 0.45 0.2 0.46 1.10 0.50 0.5 0.75 1.25 0.56 0.95 1.21 1.33 1 0.60 .1.19 1.47 1.50 0.68 1.74 2.03 1.55 0.70 1.9 2.? 1.78 .0.80 2.67 2,99 2.00 0.90 3.44 3.77 2.22 1.00 4,22 4,58 2.44'. 1.10 5.03 5.4 2.66 1.20 5.85 6.24 2.89 1.30 .6.73 7.13 8.11 1.40 6.75 7.17 3.33 1.50 6.44 6.87 3.55 1.60 6.13 f 6.58 3.77 1.70 5.84 6.3 4.00 1.80 5.54 6.02 4.22- 1.90 5.26 5.75 4.44 2.00 4.99 5..55 2.50 3 4.28 6.66 3.00 2.56 3.18 7.77 3.50 1.5 2.17 8.88 4.00 0.51 1.23 10.00 4.50 -0.42 0.34_ MP PLAN LAT pLOLL LIIC is b 4 7�q 01% lit Mt. Lh MISC DETS e-7-7= F 2 TNO 0 mT m m AM GENFRAI DRAWNG A VG' ►t►e� i 7z Q p ►I���1 bf(lClflFGI YSHSAJOSIt� A II �Yii� ¢ Ii -- �G9WRFLIIAS� I I ill .m. u 3/7/2006 8:16:01 AV, 3MEDS.p J F ==zz" , r - � - n M n UITUMINOUS PAVEMENT SECTION r i1 TYP. CONCRETE PAVING SECTION M- *16 m 74� W_ rI CONCRETE PAVEMENT t JOINS rl GUARD POST DETAIL -a- -�T - TYPICAL WALL SECTION 9 v (1 SECTION THRU CONCRETE PAVING 4 -- -- MISCELLANEOUS DETAILS Y9 9ci§ uuc LOT 'C' TRAILER STAGING AREA a ° Me. CORPORATE INCINERATOR CHEM 888- C -664K Q SECTION — CONTAIMENT SUMP 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) Nan -3M Wastes Allowed A condition that 3M may accept only bulk wastes with high BTU content from non -3M wastes. All non -31VI 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: 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: L 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 11th day of August, 2010. Myra Bailey Mayor, City �bttagarove State of Minnesota County of Washington This instrument was acknowledged before me on �q - L ) -•�'�� by Myron Bailey, Mayor of the City of Cottage Grove. "mod m. xa-0-4L4� Notary Public - f',r'i —ck,�� far Vickie Batroot Site Director, 3M Cottage Grove 1- r✓ r- .- rl- iisr- t✓lrr rf �� s1✓r � r✓..r � State of Minnesota County of Washington This instrument was acknowledged before me on ��tS j a �- - b Vickie Batra t, Site Director of 3M Cottage Grove. PATRICIA K. DILLON NOTARY PUBLIC . MINNESOTA Notary Public ;4 My Se6lision Exores Jan. 3 Page 3 of 3 RESOLUTION NO. 2010 7 118 APPROVING MEMORANDUM OF UNDERSTANDING REGARDING 3M CORPORATE INCINERATOR AIR MONITORING 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 positlye 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 August 11, 2010 is hereby adopted, Passed this 11 th day of August 2010. Myrg4 a ey, Ma Sr Attest: Caron M. Stransky, City Clerk