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Home My WebLink About2013-01-16 PACKET 04.M.REQUEST OF CITY COUNCIL ACTION COUNCIL AGENDA MEETING ITEM # DATE 1/16/13 • & 1 0 ... 1 . Community Development ORIGINATING DEPARTMENT Jennifer Levitt STAFF AUTHOR COUNCIL ACTION REQUEST Consider providing a response to the Minnesota Pollution Control Agency (MPCA) on the Draft Air Permit for 3M Cottage Abrasives Systems Division. STAFF RECOMMENDATION Send the response to the MPCA on the draft Air Permit for 3M Cottage Grove Abrasives Systems Division. BUDGET IMPLICATION $N /A $N /A N/A BUDGETED AMOUNT ACTUAL AMOUNT FUNDING SOURCE ADVISORY COMMISSION ACTION DATE REVIEWED APPROVED DENIED ❑ PLANNING ❑ ❑ ❑ ❑ PUBLIC SAFETY ❑ ❑ ❑ ❑ PUBLIC WORKS ❑ ❑ ❑ ❑ PARKS AND RECREATION ❑ ❑ ❑ ❑ HUMAN SERVICES /RIGHTS ❑ ❑ ❑ ❑ ECONOMIC DEV. AUTHORITY ❑ ❑ ❑ ® ENVIRONMENTAL 1/9/13 ❑ ® ❑ SUPPORTING DOCUMENTS ® MEMO /LETTER: Memo from Jennifer Levitt dated 1/9/13 Draft Response Letter to MPCA from Jennifer Levitt dated 1/16/13 ❑ RESOLUTION: ❑ ORDINANCE: ❑ ENGINEERING RECOMMENDATION: ❑ LEGAL RECOMMENDATION: ❑ OTHER: ADMINISTRATOR'S COMMENTS 0 r r ity Administrator Date COUNCIL ACTION TAKEN: ❑ APPROVED ❑ DENIED ❑ OTHER CITY OF COTTAGE GROVE MINNESOTA To: Honorable Mayor and City Council Ryan Schroeder, City Administrator From: Jennifer M. Levitt, P.E., City Engineer Date: January 10, 2013 Re: Approve Comment Letter to the MPCA 3M Cottage Grove Abrasives System Air Permit Background /Discussion A draft air permit for the 3M Cottage Grove Abrasives Division was published for public comment on December 21, 2012. The comment period ends on January 22, 2013. The primary operation at this facility is the processing of minerals into powders that are then applied onto abrasive products manufactured at other facilities. The 3M facility is subject to a facility -wide emissions cap, so allowable emissions from the facility will not increase as a result of this permit amendment. The City had S.E.H. review the draft permit and enclosed is a copy of the review conducted. The Environmental Commission on January 9, 2013 reviewed the permit and approved the comments noted in the attached letter regarding the minor permit language changes. Recommendation It is recommended the Council approve the comment letter to the MPCA regarding the 3M Cottage Grove Abrasives System Division Air Emission Permit No. 16300017 -004. -A SEH MEMORANDUM TO: Jennifer Levitt, PE, City of Cottage Grove FROM: Katie Hill Brandt, PE, Short Elliott Hendrickson, Inc. DATE: January 2, 2013 RE: Review of Draft Pen for 3M Cottage Grove Abrasives Systems Division SEH No. 122701 COTTG In response to your request, Short Elliott Hendrickson, Inc. reviewed the Draft Proposed Amendment to Air Pen 1630017 -004 for the 3M Cottage Grove Abrasives Systems Division (3M) facility located in Cottage Grove, Minnesota, The draft permit was published for public comment on December 21, 2012. The public comment period ends January 22, 2013. The primary operation at this facility is the processing of minerals into powders that are then applied onto abrasive products manufactured at other facilities. Draft Permit Details The proposed permit amendment would allow 3M to install a new firing line consisting of six electric tunnel ovens (also referred to as tunnel dryers) and three natural gas -fired kilns. A tunnel oven is a long, open -ended oven with a conveyor belt passing through it. Emissions from the ovens are vented to the atmosphere. Emissions from one of the kilns will be controlled by a baghouse, and emissions from the other two kilns will be controlled by a gas scrubber. A baghouse is a mechanical filter that removes particulate matter (PM or "dust ") from exhaust air. A gas scrubber uses water or a specific chemical solution to remove (or "scrub ") PM and other pollutants from exhaust air. The installation of an emergency generator would also be authorized by the permit amendment. Additionally, the proposed permit amendment would reallocate allowable emissions of PM between four u nit s at the facility in order to better reflect actual PM emissions from these units. The PM emission rates for two ovens will increase, while the PM emission rates for two kilns will decrease. Thus, the total allowable PM emissions from the facility will not change. Similarly, the proposed pen amendment would change the hourly nitrogen oxide (NOx) emission rates for two units to allow for more operational flexibility in those units, NOx emission rates for one unit will increase, while NOx emission rates for another unit will decrease. The total allowable NOx emissions for the facility will not change. The permit amendment also includes updates based on new and revised regulations. For the first time, allowable greenhouse gas (GHG) emissions and fine particulate matter (PM and PM have been documented in the draft permit. Some permit language has been updated to be consistent with recent changes to the language in the cited regulations. Findings This 3M facility is subject to a facility -wide emissions cap, so allowable emissions from the facility will not increase as a result of this permit amendment. The new baghouse must achieve at least 99% PM removal efficiency, whereas the new gas scrubber is subject to a lower PM removal efficiency requirement of 90 %. While a baghouse is a very efficient way to control PM emissions, it is not effective in high temperature or humid environments. 3M has chosen a gas scrubber to control emissions from the "indirect- fired" kilns, the exhaust from which will be either too hot or too huunid for a baghouse. Short Elliott Hendrickson Inc., 3535 Vadnais Center Drive, St. Paul, MN 55110 -5196 SEH is an equal opportunity employer I www.sehinc.com 1 651.490.2000 1 800.325.2055 1 651.490.2150 fax The MSFC (07) does not contain any regulations for immediate extinguishment if the smoke from a recreational fire is a nuisance to an adjoining property. However, many cities have language within their ordinance that requires the fire to be extinguished if someone complains about the smoke. Furthermore, some local ordinances have limitations on recreational fires when wind speeds exceed a specified amount (15 mph, 20 mph, etc.). For more information please consult with your local city or fire official. 1.2 Local ordinances Many cities choose to adopt ordinances that are more stringent than the information listed in section 1.1. For this reason, it is important to check with your city before you have a recreational fire since they may have an ordinance that goes above and beyond the requirements of the MSFC. Compliance with the above information may not mean you are in compliance with all local regulations. If you have additional questions not answered in this document please contact the State Fire Marshal Division at (651) 201 -7200. Questions can also be e- mailed to firecode @state.inn.us or view our web page at www.fire.state.mn.us for the latest information on fire in Minnesota. Review of Draft Pennit for 3M Cottage Grove Abrasives Systems Division January 2, 2013 Page 2 The draft permit and associated Technical Support Document (TSD) contain conflicting and inaccurate information regarding the required control efficiencies for the proposed new baghouse and gas scrubber. The TSD states that the gas scrubber must achieve a PM control efficiency greater than or equal to 90 %. Page A -28 of the draft permit, however, states that the new scrubber must meet a control efficiency of "less than or equal to 80 %." Instead, this should read " rg eater than or equal to 90 %," which would be consistent with the required control efficiencies of other scrubbers currently in operation at the 3M facility. Similarly, page A -30 of the draft permit states that the new baghouse must meet control efficiencies "less than or equal to" 99% for PM and 93% for PM and PM Instead, this should read, " rg eater than or equal to." The draft permit seems to have incorrectly stated the heel sulfiir content limit for the new emergency generator. Page A -26 of the draft permit states that 3M must certify "that the sulfur content does not exceed 0.50% by weight," which corresponds to 5,000 parts per million (ppm). According to federal regulation 40 CFR 80.150, the maximum sulfur content for non -road diesel Riel is 500 ppm (0.05 %) beginning June 1, 2007. As of June 1, 2010, this standard was lowered to 15 ppm (0.0015 %). To comply with this regulation, the permit should require 3M to certify "that the sulfur content does not exceed 0.0015 by weight." K MAap \\sehsb.cst.sehinc .cam \projects \ae \c \cottg \common\3m bid 112 permit \abrasives systems \cg 3m abrasives systems division firing line installation permit 01- 02- 11doex M Cottage Grove h ere Pride and?rOs perity Meet January 17, 2013 RE: Draft Air Permit, 3M Cottage Grove Abrasives Systems Division Air Emission Permit No. 16300017 -004 Ms. Sarah Seelen, Air Quality Permits Section, Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155 Dear Ms. Seelen: The City of Cottage Grove, Minnesota has reviewed the draft air emission permit for the 3M Cottage Grove Abrasives Systems Division (Permit No. 16300017 -004) and presents the following comments on the draft permit: The draft permit and associated Technical Support Document (TSD) contain conflicting and inaccurate. information regarding the required control efficiencies for the proposed new baghouse and gas scrubber. The TSD states that the gas scrubber must achieve a particulate matter (PM) control efficiency greater than or equal to 90 %. Page A -28 of the draft permit, however, states that the new scrubber must meet a control efficiency of "less than or equal to 80 %." Instead, this should be changed to read, " rg eater than or equal to 90 %," which would be consistent with the required control efficiencies of other scrubbers currently in operation at the 3M facility. Similarly, Page A -30 of the draft permit states that the new bag - house must meet control efficiencies "less than or equal to" 99% for PM and 93% for PM and PM2.5. Instead, .this should be changed to read, " reater than or equal to." Additionally, the draft permit seems to have incorrectly stated the fuel sulfur content limit for the new emergency generator. Page A -26 of the draft permit states that 3M must certify "that the sulfur content does not exceed 0.50% by weight," which corresponds to 5,000 parts per million (ppm). According to federal regulation 40 CFR 80.150, the maximum sulfur content for non -road diesel fuel is 500 ppm (0.05°/x) beginning June 1, 2007. As of June 1, 2010, this standard was lowered to 15 ppm (0.0015 %). To comply with this regulation, the permit should be changed to require 3M to certify "that the sulfur content does not exceed 0.0015 by weight." We appreciate the opportunity to review this draft permit and TSD and to provide comments. Sincerely, Jennifer Levitt, PE Community Development Director/ City Engineer cc: City of Cottage Grove Mayor and City Councilmembers Ryan Schroeder, City Administrator CITY OF COTTAGE GROVE - 12800 Ravine Parkway - Cottage Grove, Minnesota 55016 www.cottage- grove.org - 651- 458 -2800 - Fax 651.458 -2897 - Equal Opportunity Employer