HomeMy WebLinkAbout2014-05-14 PACKET 05.10.
MEMORANDUM
TO: Jennifer Levitt, PE, City of Cottage Grove
FROM: Thomas Henning, PE, SEH
DATE: May 9, 2014
RE: Review of Draft Permit at 3M Cottage Grove Abrasive Systems
SEH No. 122701 COTTG
®
At your request, Short Elliott Hendrickson, Inc. (SEH) reviewed the Draft/Proposed Air Permit for the
3M Cottage Grove Abrasive Systems Division (Abrasive Systems) facility (Permit Number 16300017-
005). The Minnesota Pollution Control Agency is accepting comments on the draft permit unit May 23,
2014.
The 3M Abrasives facility processes mineral materials into powders of various sizes for application onto
abrasive products manufactured at other facilities. The 3M Abrasives “facility” includes several buildings
at the 3M Cottage Grove complex: Building 112 (Abrasive Systems), Buildings 19 and 111 (Sintered
Abrasives) and Buildings 4, 101, and 110 (Specialty Additives). However, the Minnesota Pollution
Control Agency has issued separate permits for Abrasive Systems, Sintered Abrasives and Specialty
Additives. The proposed draft permit is for Abrasive Systems.
Overview of Draft Permit
The draft air permit is a reissuance of the facility’s Title V air operation permit. In general, this permit
allows the installation of pollution monitoring equipment, adds emission limits to existing equipment, and
adds to the permit some emission units with low emission rates. The draft permit incorporates several
amendment requests submitted by 3M to the MPCA since 2004: one major amendment, four minor
amendments and one administrative amendment.
The major amendment, received by MPCA on June 20, 2013, will make several changes to the permit.
There is no emission increase associated with these changes:
Allow the installation of two Continuous Emission Monitors (CEMs). These devices
continuously measure and record nitrogen oxide emission rates and are used by the facility to
demonstrate emissions from New Kiln #3 and Direct Fired Kiln 13 comply with allowable
emission rates.
Adds new requirements for the facility’s QC Kilns, for two diesel powered emergency generators,
and for four kiln burners: Kiln 1 Burner, Kiln 2 Burner, Kiln 11 Burner and Kiln 12 Burner. The
new requirements are from federal emission standards.
Incorporates fuel sulfur limits required to meet ambient air quality standards for sulfur dioxide.
Remove tunnels ovens that are deemed to be insignificant activities from the permit.
Grant a 120-day performance test deadline extension for the Gas Scrubber and Fabric Filter
emission control devices.
The four minor amendments will make the following changes to the permit:
Short Elliott Hendrickson Inc., 3535 Vadnais Center Drive, St. Paul, MN 55110-5196
SEH is an equal opportunity employer | www.sehinc.com | 651.490.2000 | 800.325.2055 | 651.490.2150 fax
Review of 3M Major Amendment Permit Application
May 9, 2014
Page 2
Replace an existing emergency generator with a new 99 horsepower emergency generator (May
11, 2004 Amendment). This change may result in a slight emission increase since the new
generator has a slightly higher fuel consumption rate than the old generator. The permit limits the
amount of sulfur in the diesel fuel used in the generator to less than or equal to 15 parts per
million (sometimes referred to as “ultra low sulfur” diesel fuel).
Installation of two electric rotary Quality Control (QC) Kilns to process samples from an existing
production line at the facility (April 25, 2011 Amendment). Emission increases associated with
QC Kilns are below the insignificant modification threshold. However the units are subject to a
federal emission standard. A permit modification is required to add the federal requirements to
the facility air permit.
Add requirements applicable to the Batch Oven 2, Oven 3 and Oven 4. These units are subject to
federal emission standards for calciners and dryers. There is no emission increase associated with
this amendment (June 28, 2011).
Installation of four new tunnel ovens (insignificant activities) and the installation of two
additional QC Kilns (August 13, 2012 Amendment).
Emission Increases
Emissions increases related to the draft permit are small. Many of the amendments result in no emission
increases. Other amendments have insignificant or nearly insignificant emission increases. The changes
in emission rates related to the amendments that increase emissions are shown in Table 1.
Table 1. Emission Increases from Minor Amendments
May 11, 2004 April 25, 2011 August 13, 2012 Insignificant
GeneratorsQC Kilns QC Kilns Thresholds
lb/hr
Pollutant lb/hr lb/hr lb/hr
Particulate Matter
0.21 0.015 0.015 0.855
(PM)
10
3.06 0.032 0.032 2.28
Nitrogen Oxides
Sulfur Dioxide 0.20 0 0 2.28
Carbon Monoxide 0.66 0 0 5.70
Volatile Organic
0.25 0 0 2.28
Compounds
Summary
MPCA has drafted a proposed air permit for the 3M Cottage Grove Abrasive Systems facility and is
accepting public comments on the draft permit until May 23, 2014. The draft permit will incorporate
several small changes made at the facility in addition to adding requirements to existing equipment
regulated by the air permit. The emission increases associated with the draft permit are small.
TAH/SDP
p:\ae\c\cottg\119210\draft air permit review memos\building 19 abrasive products\3m cg abrasive systems memo 9 may 14.doc