© 3M All Rights Reserved. Innovations in Permitting and Flexible Air Permitting as Well as Methods to Improve the Permitting Process Mark Manninen, 3M Environmental Operations New Jersey Clean Air Council 2010 Public Hearing April 14, 2010

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing Overview of 3M Company Creating Flexibility within Existing Permits Innovative Flexible Permits Agenda

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing Founded in 1902 and headquartered in St. Paul, MN 2008 Information Sales: $25.3 billion (>60% international) R&D and Related Expenditures: $1.4 billion Employees: 79,000 Providing over 50,000 products to multiple industries across the globe 3M Company Profile 80+ Permitted Facilities in 28 States

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing Keeping Pace with Speed of Change Lean Manufacturing Projects Formulation Changes Plant Consolidations Fuel/Energy Reduction Projects Shorter Notice Prior to Desired Construction Date Shorter Notice Prior to Desired Construction Date Average Permit Project Lead Time

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing Synthetic Minor Source Permitting Providing Regulatory Options Creative Permit Language Creating Flexibility within Existing Permits

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing Low VOC Coating Example: Regenerative Thermal Oxidizer BACT = 96% Overall Control of VOCs 4% VOC to Atmosphere Creative Permit Language

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. 3M Innovative Flexible Permits 3M St. Paul Main – First Innovative Flexible Permit Issued in 1993 Current Flexible Permits 3M Brownwood (Texas) 3M Nevada (Missouri) 3M Menominee (Wisconsin) US EPA Flex Permit Rule - Issued September 25, 2009

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. Flexible Permit Basics Title V Permit with additional provisions to allow for certain pre- approved changes in return for beyond compliance commitments Prescriptive permit requirements address all applicable air regulations (MACT, NSPS, NAAQS, State Regs, etc.) Pre-approved changes to be completed without traditional construction permit authorization and timeline

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. Benefits of Flexible Permits Allows Permittee to rapidly react to business needs Reduced administrative burden for agency and Permittee Provides Permittee with incentive to reduce environmental footprint

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. Case Study – 3M Menomonie Diverse facility manufacturing products for >15 different 3M Divisions Initial flexible permit issued in 2004 and renewed in 2008 Benefits 16 flexibility projects implemented since 2005 Significant time and resource savings for 3M and WDNR Environmentally beneficial projects and partnerships

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. Case Study – 3M Menomonie Example of Title V Permit language additions required for installation of several web coating lines

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. Case Study – 3M Menomonie VOC Emission Reductions Actual VOC lb emissions vs. 1,000 lb or product output

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing © 3M All Rights Reserved. Future Need for Flexible Permitting Reductions in both industry and agency resources will require more innovative permitting approaches Economic uncertainties impact on the speed of business Great opportunity to promote voluntary environmental programs

NAEM Forum – 3M Employee Engagement New Jersey Clean Air Council – 2010 Public Hearing Questions ?