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Air Quality Standards: Compliance & Reduction Strategies
Chris Nelson, P.E.3M Environmental, Health, and Safety Operations
3M Environmental, Health and Safety Operations
2
Overview Federal Standards: Where Does Minnesota
Stand? Nonattainment Experience 3M’s Pollution Prevention Pays Program
© 3M 2010. All Rights Reserved.
3M Environmental, Health and Safety Operations
3
© 3M 2010. All Rights Reserved.
Minnesota Ozone Levels
Shako
pee
(505
)
Detro
it Lak
es (2
013)
Mille
Lac
s (30
51)
St. Clo
ud (3
052)
St. Mich
ael (
3201
)
Brain
erd
(320
4)
Mar
shal
l (42
10)
Roche
ster (
5008
)
Stant
on (5
302)
Blain
e (6
010)
East B
ethe
l (60
12)
Stillwat
er (6
015)
Ely (7
001)
Cloqu
et (7
416)
Dulut
h (7
550)
Voyag
eurs
N.P
.0
10
20
30
40
50
60
70
80
60 59 59 58
62 6163
60 60
6563 62
58
54
49
62
2009-2011
Standard
Ozo
ne
Co
nce
ntr
atio
n (
pp
b)
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4
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Minnesota Particulate Matter Levels
Apple
Valley
(470
)
Minn
eapo
lis (9
63)
St. Lo
uis P
ark
(250
)
Roche
ster
(500
8)
St. Pau
l (86
8)
St. Pau
l (87
1)
Virgini
a (1
300)
Duluth
(755
0)
Duluth
(755
1)
Shako
pee
(505
)
St. Clou
d (3
052)
0
5
10
15
20
25
30
35
40
3130
28
30
3433
17
19
21
2827
2009-2011
Standard
PM
2.5
Co
nce
ntr
atio
n (
µg
/m3
)
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5
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Products
3M Environmental, Health and Safety Operations
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Example: Printing Press Minor source for Title V, New Source Review Ozone nonattainment area Emissions – Volatile Organic Compounds
(VOC) Potential emissions: less than 5 tons per year Actual emissions: less than 1 ton per year
Control equipment required (“RACT”) $25,000 – 45,000 per year
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Example: Sponge Making Major source for Title V, New Source Review Ozone nonattainment area Proposed 1 lb/hr VOC increase Requirements driven by applicable emissions
limit (RACT) Permit change and SIP revision required for insignificant
change; added 6 months to project
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3M Environmental, Health and Safety Operations
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Example: Insignificant Units Minor source for Title V, New Source Review Ozone, PM nonattainment area Compliance notice for failure to register
cafeteria “char griller” Facility registered unit and paid permitting
fees; ongoing recordkeeping required
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3M Environmental, Health and Safety Operations
9
© 3M 2010. All Rights Reserved.
Pollution Prevention Pays (3P)
“Pollution is … unused raw material. By reducing the amount of pollution, … [3M can] save money both on pollution control and on raw materials the next time around. It's a win-win situation.”
Dr. Joe Ling launched 3M’s 3P program in 1975
1975-2011 Totals
Total Projects
Total Monetary Benefit ($USD)
Total Pollution Prevented (US lbs)
9,324 1.56 Billion 3.57 Billion
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10
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Pollution Prevention MethodsMethod Description
Product Reformulation • Replace a part of entire product with less or no toxic chemical(s)
Process Modification • Alter a manufacturing process to reduce pollution (air, water, waste)
Equipment Redesign • Redesign of equipment with new concept to reduce pollution
Quality/Yield Improvement
• Improve efficiency with reduced defects or use fewer raw materials to reduce waste
Recovery and/or Reuse • Develop/Improve system to recover or re-use waste stream
New Product • Develop product with environmental attribute/benefit to assist customer with reducing pollution
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3P Case Study: License Plate System
3M Traffic Safety Systems Division
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Conventional Manufacturing
Plate Blanking
Reflective Sheeting
Ink Curing
VOC Emissions
Graphic Printing
Aluminum Substrate
Plate Embossing
Roll Coating
Ink Curing
Bagging and
Shipping
VOC Emissions
3M Environmental, Health and Safety Operations
13
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Digital Manufacturing
Plate Blanking
Reflective Sheeting
Ink Curing
VOC Emissions
Graphic Printing
Aluminum Substrate
Plate Embossing
Roll Coating
Ink Curing
Bagging and
Shipping
VOC Emissions
3M Environmental, Health and Safety Operations
14
Environmental Results 2010 3M Environmental Targets
Reduced volatile air emissions per net sales by 31% (goal: 25%)
Reduced waste per net sales by 19% (goal: 20%)
Improved energy efficiency per net sales by 26% (goal: 20%)
2621 Pollution Prevention Pays projects (goal: 800)
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3M Environmental, Health and Safety Operations
15
Summary Minnesota air quality is good; changes to
standards may trigger new requirements Nonattainment risk
More requirements and complexity Less flexibility and choice
Opportunities exist for all of us to proactively reduce our emissions
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