HomeMy WebLinkAbout2015-05-13 PACKET 05.1.Branding a Better World
for A,IIII of Us'
TO: Jennifer Levitt, PE - City of Cottage Grove
FROM: Thomas Henning, PE
DATE: May 7, 2015
MEMORANDUM
RE: 3M Cottage Grove Environmental Compliance Document File Review
SEH No. COTTG 122701
At your request Short Elliott Hendrickson, Inc. (SENO) has reviewed the past three years of compliance
submittals and inspection reports (covering the period from April 2012 to February 2015) for the 3M
facilities operating at 3M Cottage Grove. The documents include deviation reports and compliance
certifications required by the air quality permits, Minnesota Pollution Control Agency (MPCA) inspection
reports for air quality and water quality compliance, and Washington County Public Health and
Environment hazardous waste compliance inspection reports. Below is a summary of the information
which was reviewed.
AIR QUALITY COMPLIANCE SUBMITTALS
The 3M Cottage Grove facility holds eight separate air quality permits for various manufacturing
processes. Each permit requires the submittal of one or more of the following: quarterly excess emissions
reports, semiannual deviation reports, and routine performance test reports. A summary of each separate
facility's compliance submittals is provided below and in the attached tables.
Abrasive Systems Division
The Abrasive Systems Division received an Administrative Penalty Order and $500 fine following a 2012
engineering test which resulted in an exceedance of a nitrogen oxides (NOx) emission limit. Subsequent
testing showed compliance with the NOx limit. 3M amended their permit with new NOx limits and installed
a continuous emissions monitoring system (CEMS) to guarantee future compliance.
In 2014, the MPCA issued a Notice of Violation (NOV) for installing a unit prior to submitting a minor
permit application. (Generally, a facility can make their requested changes seven days after the submittal
of a minor permit application.) 3M had submitted a permit application for the installation of two new kilns;
however, three kilns were installed. 3M reported the violation to MPCA when it was discovered. The NOV
required the facility to submit a signed document citing that future modifications will meet the state
notification requirements. No further action was required.
A summary of the Abrasive Systems Division compliance documents is attached in Table 1.
Film and Automotive Divisions
Compliance documents reviewed for the Film and Automotive Divisions show minor reported deviations
from baghouse operating and recordkeeping requirements. No Notices of Violation or Enforcement
Actions were issued to the Film and Automotive Divisions during the period of review.
Engineers I Architects I Planners I Scientists
Short Elliott Hendrickson Inc., 809 North 8th Street, Suite 205, Sheboygan, WI 53081-4032
SEH is 100% employee -owned I sehinc.com 1 920.452.6603 1 888.908.8166 fax
3M Cottage Grove Environmental Compliance Document File Review
May 7, 2015
Page 2
Corporate Incinerator
Excess emissions and permit deviations for the Corporate Incinerator were noted during each reporting
period included in the records review. All excess carbon monoxide (CO) emissions episodes, as
measured by a CEMS, were followed up with corrective actions. The majority of the excess emission
episodes (83%) occurred during startup or shutdown of the incinerator, when no waste was present in the
unit. The remainder of excess emission episodes were caused by instantaneous malfunctions of the
system. The annual CO emission limit for the incinerator is 94.6 tons averaged over 12 months (12 -month
rolling average). Actual CO emissions during the period of review (January 2012 - June 2014) averaged
1.5 tons per 12 months. The short-term CO emission limit is 100 parts per million (ppm) averaged over
one hour (one-hour rolling average). Actual CO emissions during the period of review (January 2012 -
June 2014) averaged 2.38 ppm per hour.
The highest CO emission deviation reported was 889 ppm, which occurred during an excess emission
period that lasted for 2 hours, 49 minutes when extremely cold ambient temperatures caused the natural
gas regulator to stop working, leading to a loss of temperature in the kiln. The longest CO emission
deviation reported occurred for a period of 33 hours, 12 minutes with a high CO reading of 212 ppm
during an incinerator startup event, during which no waste was incinerated. A summary of the excess
emissions events are provided in Table 2.
A variety of minor permit deviations were also reported for the Corporate Incinerator on each required
Semiannual Deviation Report. Deviations occurring more than once during the period of review include
(a) "slag events" causing over pressurization in the kiln, which caused the emergency stack to briefly
open, and (b) visible emissions observed during the loading of lime into the storage silo. No Notices of
Violation or Enforcement Actions were issued for the Corporate Incinerator air permit during the period of
review.
Materials Resource Division
No Notices of Violation or Enforcement Actions were issued for the Materials Resource Division during
the period of review. Additionally, no excess emissions or deviations were reported.
Specialty Additives
Specialty Additives received an Administrative Penalty Order and $1,000 fine in 2014 following a 2011
emissions test which resulted in an exceedance of a particulate matter (PM) emission limit. The facility is
required to either amend their permit to reflect the higher rate of PM emissions measured during the
emission test, or agree to not use a specific product formulation in the facility's agglomerator system
process until a time that improved control exists to capture the higher PM emissions. A draft revision to
the facility's air permit was published for public comment in March 2015. The revised permit modifies
several emission limits, changes compliance demonstration methods, and adds new requirements for
some of the emission units. No emission increases are associated with this permit.
A summary of the Specialty Additives compliance documents is attached in Table 3.
Tape Manufacturing
No Notices of Violation or Enforcement Actions were issued for the Tape Manufacturing facility during the
period of review. Additionally, no excess emissions or deviations were reported.
Traffic Safety
A number of minor permit deviations were reported regarding recordkeeping requirements for emission
control monitoring devices at the Traffic Safety facility. Corrective actions included replacing the
monitoring devices with electric devices and updating the facility's Operations and Maintenance (O&M)
3M Cottage Grove Environmental Compliance Document File Review
May 7, 2015
Page 3
Plan to more easily comply with their air permit requirements. No Notices of Violation or Enforcement
Actions were issued for the Traffic Safety facility during the period of review.
Utilities Support Services
No Notices of Violation or Enforcement Actions were issued for the Utilities Support Services facility
during the period of review. Additionally, no excess emissions or deviations were reported.
AIR QUALITY COMPLIANCE INSPECTION REPORTS
The MPCA has conducted five air quality compliance evaluation inspections at the 3M campus over the
past three years. Lapses in recordkeeping were noted during two of the inspections, as noted in the
attached Table 4. No other violations were observed.
WATER QUALITY COMPLIANCE INSPECTION REPORTS
MPCA water quality staff conducted a compliance evaluation inspection of the 3M — Chemolite
Wastewater Treatment Facility on August 28, 2012. 3M's compliance with the MPCA Multi -Sector General
Permit for Industrial Stormwater was also reviewed as part of the inspection. During the inspection, MPCA
staff noted that a water quality effluent limit for total residual chlorine was incorrectly stated in the permit;
the limit will be changed in the next reissued permit. No violations were noted.
HAZARDOUS WASTE COMPLIANCE INSPECTION REPORTS
Washington County Public Health and Environment has conducted several hazardous waste compliance
inspections over the past three years for both the Corporate Incinerator, which is defined as a "treatment,
storage and disposal facility" under Resource Conservation and Recovery Act (RCRA) rules, and the
entire facility, which is defined as a Large Quantity Generator (LQG) of hazardous waste (i.e. generates
1,000 kilograms per month or more of hazardous waste).
SEH obtained inspection records for six of the seven hazardous waste inspections conducted by
Washington County between April 2012 and February 2015, the details of which are provided in the
attached Table 5 and Table 6. LQG facility inspections occur about once a year. Corporate Incinerator
inspections occur at least once a year. All of the Corporate Incinerator inspections were noted as
"unannounced;" MPCA accompanied Washington County on one of these inspections. For all perceived
deviations or violations noted during each inspection, Washington County and/or MPCA requests that 3M
supply additional information or make amendments to their standard operating procedures. One Notice of
Violation (NOV) was issued to the Corporate Incinerator during the period of review. As a response to the
NOV, 3M implemented corrective actions to address the violations, and MPCA closed out the NOV
without taking further action. Details regarding the NOV and corrective actions are provided in Table 6.
KH B/TAH
Attachments:
Table 1. Abrasive Systems Division Compliance Reporting Summary
Table 2. Corporate Incinerator Compliance Reporting Summary
Table 3. Specialty Additives Compliance Reporting Summary
Table 4. Air Quality Compliance Inspection Reports Summary
Table 5. Total Facility Hazardous Waste Compliance Inspection Reports Summary
Table 6. Corporate Incinerator Hazardous Waste Compliance Inspection Reports Summary
s:\ae\c\cottg\common\3m cg mpca file review - march 2015\april 2015 cgmemo_3m env file review_ 04.22.2015.docx
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