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FREE SPEECH ZONE | Will the MPCA "Citizens' Board" side with citizens and the environment?
The "Citizens' Board"--essentially, the Board of Directors--of the Minnesota Pollution Control Agency meets on Tuesday, May 22, 2012. The two main decision items involve requests from citizens to invoke the Minnesota "Environmental Review" process. That is, they are petitions for an "Environmental Assessment Worksheet" to be prepared for two projects. In both cases the MPCA is urging the Citizens' Board to say NO to the citizens. As far as I can tell, NO is now the standard response of the MPCA to such citizen requests. Will the Citizens' Board stand with the citizens or the MPCA bureaucracy? You can watch the meeting live online: http://www.pca.state.mn.us/index.php/view-document.html?gid=17696
The first of these involves a scheme to dump up to 31 thousand pounds of "taconite powder" into Rush Lake with the stated intent of either making the water clearer and/or reducing aquatic weeds. How many pounds of toxins could be dumped into the lake? Nobody seems to know. The MPCA says the EAW should be denied based on a "research and data collection" exemption in the Minnesota Environmental Policy Act. But, no data is to be collected on before-and-after water clarity. (Lake sediments would be analyzed but what would this tell us about the clarity of the water or the health of the disliked plants?) Don Arnosti, Policy Director, Audubon Minnesota, is the petitioners' representative. The petition suggests the real purpose is to kill Curly-leaf pondweed, a non-native invasive plant. But such treatment is illegal, because the taconite powder concentrate is, obviously, not registered as an herbicide for this purpose. Arnosti called it "an illegal application of an unregistered pesticide." Why would the MPCA want to support such an activity ....? Read more here: Board packet - Decision item: Rush Lake Iron Augmentation Project
The request for further study of this scheme seems well-justified.
The second Citizens' Board agenda item is the request of the Coalition of Concerned Cottage Grove Citizens for an EAW review of the proposed increased waste-burning at the 3M Corporate Hazardous Waste Incinerator in Cottage Grove. Leaders of the coalition include former 3M executives and engineers. I've written about this quite a bit already. For example, "...Cottage Grove, Minnesota, needs a little help." Over four hundred people signed the petition for an EAW for the 3M burner. That there should finally be an environmental review of the burner seems like a no-brainer to most people, but the MPCA has cooked up 188 "Findings of Fact" and "Conclusions of Law" as to why the EAW petition should be denied. To me it all reads a lot like: "The MPCA defers to the political clout of 3M Company."
Action Item: Have an opinion on this? Send it to the MPCA Citizens' Board: citizensboard [dot] pca [at] state [dot] mn [dot] us .
Recently leaders of the Coalition of Concerned Cottage Grove Citizens met with the new MPCA Commissioner John Linc Stine. This statement was presented by Fred Luden, Chair of the Board of Directors of the Coalition:
Good Morning Commissioner Aasen and members of the MPCA. On behalf of our Board I would like to thank you for taking time from your busy schedules to meet with us.
My name is Fred Luden. Prior to my retirement as a Manufacturing and Supply Chain Director in 2007, I spent 42 years working in industry with almost 36 years working for 3M Company. For 3 years of my career I was the site director at the 3M Cottage Grove Center and for six years of my career the 3M Cottage Grove Hazardous Waste Incinerator reported into my organization. Unlike the individuals before or those since who held the position of site director, I chose to live in Cottage Grove. I am just a resident stakeholder in our community. I am also a member of the Coalition of Concerned Cottage Grove Citizens.
Joining me this morning we have our distinguished State Senator, Katie Sieben. Let me introduce the other Coalition members; Bruce Gengnagel, Bets Thorkelson, Floyd Ott, Pam Ott, Laurie Ott, Del Eilers, Susan Luden, Morgan Jenkins, Tony Huber, Kathy Houstons, Rachel Derbis Benson, Tony Jurgens, and Brian Dealy. In addition we have Alan Muller who is a consultant retained by the Coalition. We are a serious, professional organization. In the group today we have over 125 years of 3M experience. We have as much or more knowledge on 3M operations and 3M systems than anyone at the MPCA. That would be true even if Sheryl Corrigan was still the commissioner. We have as much or more knowledge about the 3M Cottage Grove Hazardous Waste Incinerator operations and financials than anyone at the MPCA. We also have detailed technical knowledge on the 3M Cottage Grove Hazardous Waste Incinerator. One of the individuals here today recently retired from the 3M Cottage Grove Hazardous Waste Incinerator as a Senior Process Engineer.
I mention this not from a position of arrogance, but one of clarification. Discussions took place between the MPCA and 3M in 4Q08. From the FOIA we have a document in hand that states in February 2009, 3M requested a minor permit amendment to allow use of non-3M supplemental fuel waste as an alternate fuel at the 3M Cottage Grove Hazardous Waste Incinerator. In it 3M states "At the request of the MPCA, we are also asking to allow 3M to process regulated hazardous wastes from Minnesota Law Enforcement." This definitely sounds like this idea it was not initiated by 3M. In April, 2009 3M holds a public meeting and it is the first time that the citizens are aware that a major permit modification is being proposed to bring in non-3M hazardous waste and Minnesota Law Enforcement Waste. Individuals throughout the community started to voice concerns. Several of us have had extensive training in risk management and risk management communications. We were shocked that the MPCA and 3M were working together in justifying this permit modification. Some of the analogies for communicating risk were calculated and provided to the MPCA by 3M. We challenged the proposal, the justification for the change, and the MPCA/3M risk management communication. I was personally lectured several times by MPCA personnel on 3M operations and financial systems. As a result the Coalition of Concerned Cottage Grove Citizens was formed. As residents we felt our concerns were being marginalized in the press by 3M and the MPCA as a small group of citizens whose opinion is not widely shared. As time went on, we have been classified as "uniformed", "lacking the ability to understand the technical issues", "not respectful", and "fear mongers". We felt the accusations did not dignify a response and have focused on the permit process. It is our hope that when we leave today you will understand that those accusations were not true and used as distractions.
The Coalition decided to quantify how Cottage Grove residents felt about the proposed permit change. At great personal sacrifice, about 40 Coalition members hired Decision Resources to do a Community Survey. Decision Resources is a firm used by 3M Company, the City of Cottage Grove, and our local school district. The survey was conducted in December 2009 and January 2010. We were not sure of how the survey results would come out, but we were hopeful if a large majority of the citizens opposed the major permit modification being proposed to bring in non-3M hazardous waste, it would be withdrawn. The survey results show that 2 out of 3 residents oppose the 3M proposal and even more significant almost 3 out of 4 Cottage Grove homeowners oppose the 3M proposal. The only anomaly in the survey was that one group was 83% favorable to the proposal, 3M Cottage Grove employees. We have brought a copy of the survey for you.
The current language in the Incinerator Air Permit "The 3M Corporate Incinerator provides treatment and storage for business related wastes generated by 3M's operating divisions in North America" identifies the current restriction. The current language in the wastewater treatment NPDES Permit states "The 3M hazardous waste incinerator is located at the 3M Cottage Grove Center where hazardous wastes from other 3M plants in the U.S. may be incinerated" also reflects the current restriction. Both permits contain language that is clearly consistent with the original agreement between the Village of Cottage Grove and 3M Company.
Logic dictates that the restrictions in both permits were requested by the city of Cottage Grove on behalf of the citizens and was agreed to by 3M and the MPCA. Therefore it should take the city of Cottage Grove, on behalf of the citizens, to agree to remove these statements which will end the citizen's only local control. It has been stated new restrictions cannot be put into the permit without first being agreed to by 3M. If this is so, how can the only restriction put in the permit by the city of Cottage Grove, on behalf of the citizens, be removed without the city's agreement? The survey is clear that the residents oppose 3M's permit modification request.
Our mission is to have the permit change to allow burning of non-3M waste denied. Cottage Grove residents have been willing to be the home of the only hazardous waste incinerator in the state because it was business related waste from 3M sites in North America. 3M would be employing people at these locations, hopefully in the United States, and 3M would be producing products that we would all be using. A win-win scenario. Bringing in liquid hazardous waste from a fuel blender that is so contaminated it can't be reused or recycled to burn in our community to save some money is a win-lose scenario.
As this process has carried out over the past three years the Coalition of Concerned Cottage Grove Citizens has felt as if we are a David against two Goliaths in the MPCA and 3M who both have tremendously more financial, legal, and human resources than our small citizen's organization. But there is one big difference. We are passionate stakeholders who live in this community.
We have asked ourselves who will be the winner if this permit modification is approved. It reminds you of a riddle; if a cheated man is a loser and cheaters never win - who is the winner. This is the way the citizens feel when dealing with 3M Waste Management Practices and the MPCA. There have been no winners, and only the citizens have been the losers.
We have five things we would like to cover with you today:
3M Waste Management Practices and MPCA Regulations have not protected the citizens or the environment.
It isn't just about the water. It is about the process of waste management that has not worked.
1950 - 1960's 3M Waste Management practices complied with the rules and regulations in force at that time. 3M Waste Management used contractors and 3M waste was dumped into landfills. This included liquid waste.
Late 1960's - Volatile Organic Compounds are found in private wells around what is now called, the Woodbury landfill, by the residents noticing a smell in their drinking water. 3M is authorized to set fire to the waste at the landfill.
1970's - 3M Waste Management drills barrier wells at the Woodbury landfill and is authorized to send the water to 3M Cottage Grove to be used as non contact cooling water and then discharged into the Mississippi. 3M is authorized to put an impervious cap over the landfill to prevent rain going through the contaminated soil and into the aquifers.
3M uses its influence so Woodbury and Cottage Grove obtain the easements for the water pipe from the Woodbury Landfill to 3M Cottage Grove.
1970's 3M tells the MPCA and Cottage Grove that they need to build a Hazardous Waste Incinerator at Cottage Grove to burn their hazardous waste or the future of the St. Paul and Cottage Grove manufacturing plants is at risk. 3M states the majority of the waste will be generated at 3M Cottage Grove and that the incinerator should be viewed as a pollution control device. As a result the incinerator equipment is made tax exempt and the incinerator is located at 3M Cottage Grove. The Cottage Grove city council agrees to a land use permit on the condition that it is only used for 3M waste and only for high Btu liquid hazardous waste with pumpable at 13,000 Btu per pound and non-pumpable at 10,000 Btu per pound.
1972 - 3M Waste Management receives an operating permit from the MPCA and the 3M Hazardous Waste Incinerator starts operation in Cottage Grove and the 3M crisis is solved.
1978 - 3M operates seven Incinerators in the United States designed specifically for the disposal of pumpable hazardous waste. Three of the six could also destroy solid hazardous waste and extra hazardous scrap. They are located in Brownwood Texas, Cordova Illinois, Cottage Grove Minnesota, Decatuer Alabama, Hartford City Indiana, Nevada Missouri, and White City Oregon. Cottage Grove had a 90 million Btu incinerator with a kiln temperature of 1100 degrees Fahrenheit and secondary combustion chamber of 1600 degrees Fahrenheit.
Now we move forward forty years and see how well things have worked out.
2012 - Barrier wells are still pumping water at the Woodbury landfill. Using a conservative estimate over the past forty years 3M has pumped 51,000,000,000 gallons of tax free water. The water is still pumped through the pipeline to 3M Cottage Grove to be used as non-contact cooling water and discharged into the Mississippi. Pfcs have been found in the ground water, surface water, and soil. Consent orders are in place and remediation is underway. Dirt has been dug up, the river dredged, water is being treated and more will be treated. Fish advisory exists in the river by the 3M Cottage Grove plant.
The St Paul manufacturing plants have been closed and 3M Cottage Grove employment is a fraction of what it once was.
Over the years the regulatory permits and the City of Cottage Grove conditional land use permit have been modified to allow 3M to burn anything from anywhere in North America related to the manufacture or distribution of 3M products. The 3M Cottage Grove Hazardous Waste Incinerator can burn all forms of hazardous waste; liquid, sludge, solids, and gas. They are allowed to burn water waste with zero fuel value. Considerably less than half the hazardous waste comes from generators within the state of Minnesota and 3M Cottage Grove is now a small percentage of the waste burned in the 3M Cottage Grove Hazardous Waste Incinerator. 3M Cottage Grove maintains a tax exempt status on the hazardous waste incinerator equipment, but it still only burns 3M waste.
Of the seven sites with incinerators in 1978, all the incinerators have been closed except for Cottage Grove Minnesota. The White City Oregon facility was sold, but the rest are still 3M facilities. Several are much larger generators of Hazardous Waste than the Cottage Grove site. Since 1970 the 3M Cottage Grove Hazardous Waste Incinerator has burned approximately 1,900,000,000 pounds of waste.
In 1997 - 1998 3M Waste Management sent a team of engineers to the 3M Cottage Grove Hazardous Waste Incinerator to increase throughput and increase capacity. In 2000 the 3M Cottage Grove hazardous Waste Incinerator was replaced with a new unit and after much negotiations was classified as an existing source for MACT standards. New handling equipment was installed to increase throughput. The kiln size was increased by 33%. The stack height was reduced by 25%.
In the first 7 years of operation the 3M Cottage Grove hazardous Waste Incinerator processed an average of 62,400,000 lb of waste a year. The original incinerator would have processed between 45,000,000 and 50,000,000 pounds a year. We now burn more, faster with a shorter stack.
Even though the MPCA regulated the Woodbury Site and 3M met all the regulations Cottage Grove residents have Pfcs in their drinking water, in the river, in the soil, and in their blood.
The State of Minnesota is suing 3M for an estimated $1,000,000,000 claiming they damaged the state's natural resources. MPCA set the regulations and 3M claims it met all the regulations. The Metropolitan Council is suing 3M and 3M states that not all Pfcs in the wastewater are theirs.
Here we are forty years later, as a result of 3M Waste Management Practices and the regulations in force at the time, there is a large unexpected environmental issue. Everyone claims they did the right thing, but the losers are the citizens. The expense for the lawsuit alone will be staggering.
More will be spent litigating this one issue than could be saved by 3M in fuel cost and by Minnesota Law Enforcement waste disposal cost for the next twenty years with this permit change.
Hopefully you can understand why we do not believe 3M Waste Management programs are a success. We also don't believe that regulations guarantee citizens health or safety. We believe they just determine a level that a company can pollute at without being fined.
For example dioxin was not regulated at the incinerator until 2000 with the new MACT standards. 3M claims this permit modification is to save money on natural gas. 3M costs are more impacted by CoGentrix (cogeneration facility) who supplies steam to the 3M Cottage Grove site. When CoGentrix is not supplying power to the grid they use auxiliary boilers burning natural gas. In the 2001 - 2003 timeframe when natural gas was close to $11 the 3M Cottage Grove steam bill was close to $1,000,000 a month during the winter months.
3M did not put a waste heat recovery boiler on the new incinerator, but there was one on the old incinerator. 3M knew they could not meet the Dioxin emissions limit for MACT if a waste heat boiler was installed. So how high were dioxin emissions over the life of the old incinerator? There are members of the Coalition who believe that there two neighborhoods River Heights/River Acres and Pine Coulee that have an extremely high level of cancer and breast cancer in particular. When they ask questions they are given county wide data and all the citizens are asking is someone to look at their neighborhood. Some are adjacent to the facility. If they ask more questions, they are then given some analogy and told it is OK.
Rita Messing, who he believes is extremely concerned about pollution, said her department sets the standards for what's healthy, and has told him that "we can rest assured that 3M has so many cleaning devices (scrubbers) put in place that we have nothing to be concerned about."
John Soler told me that barrel burners give off more dioxins that the incinerator ever will.
Does anyone believe a seldom used barrel burner has emitted more dioxin than living in an area of air inversions with a Hazardous Waste Incinerator emitting dioxins for forty years? This process of people in Government Agencies trying to sell risk adds to the citizen's frustrations.
Should a Hazardous Waste Incinerator been built in this location and should it be expanded?
If a company, even 3M, wanted to open a new hazardous waste incinerator to process just the additional non-3M material and law enforcement waste would it be permitted? If the current incinerator didn't exist would the current location meet the criteria for locating a Hazardous Waste Incinerator? Many smaller countries and the World Health Organization have published guidelines for site selection.
Avoid areas with thermal inversions which prevent safe dispersal of contaminants
during operation or during an accidental release.
Avoid areas with significant rainfall and snow.
Avoid wetlands and river areas.
Avoid sensitive or environmentally stressed areas.
Avoid populated areas downwind, especially if thermal inversions exist.
Thermal Inversions should be looked at in detail by the MPCA. Montana has in its Hazardous Waste Incinerator regulations that under certain atmospheric conditions burning of hazardous waste has to stop.
The current location was not chosen because it was a good decision for the environment or for the citizens. It was chosen because 3M had a Waste Management Emergency and they wanted it on the site where, at that time, a large amount of the waste was generated and the equipment would be tax exempt.
What is the real reason for the permit change? What is the truth?
Now the MPCA and 3M want to take out the language in the permit that has restricted the use of 3M Cottage Grove Hazardous Waste Incinerator to burning just 3M waste. What is the real reason for this change? The citizens want to know the truth.
We have been told 3M will save money on natural gas as a reason for this permit change.
April 2009 - 3M states it will save $750,000 and enough natural gas to heat 2000 homes.
April 2012 - 3M states it will save $2,000,000 and enough natural gas to heat 2000 homes.
The same quantity of natural gas, but between 2009 and 2012 natural gas prices have fallen 75% and 3M savings increased 167%?
We have been told that 3M had a sharp reduction in fuel grade liquid hazardous waste as a result of waste reduction at the generator plants. There was a sharp reduction in the Hazardous Waste Incineration Industry as a result of the economic downturn. Clean Harbors Hazardous Waste Incinerator in Utah was fined in 2009 by Utah Environmental Quality Board. The fine was reduced by 40% to reflect the economic downturn and the significant reduction in waste coming into the plant.
3M Cottage Grove hazardous Waste Incinerator operating hours as reported to the MPCA; 2008 - 6,849.8, 2009 - 5,622.4, 2010 - 5,712.6, 2011 - 6,700.4. It appears that the operating hours have gone back up as the economy improves. It should not be the responsibility of the MPCA to change a permit to allow increased pollution as a result of a general economic condition that impacted the country. The current permit allows 3M to make an acquisition anywhere in North America and bring large amounts of additional hazardous waste to the 3M Cottage Grove Hazardous Waste Incinerator. It would be more appropriate for the MPCA to realize it is the owner's responsibility, 3M Cottage Grove Hazardous Waste Incinerator, to shut down in order to conserve resources and reduce costs in economic slowdowns. This common sense business practice would save Natural Gas, eliminate the need for auxiliary fuel, and reduce pollution.
We have been told that 3M will only need one or two additional tank trucks to replace what it has lost. The proposed permit uses 5,000 Btu per pound in the worst case calculation. If we use the 400,000 million Btu stated in the permit as the amount of increase, and 5,000 Btu per pound it amounts to 5.5 tanker trucks per day 365 days a year. If use the definition previously used in permits to define the waste;
Fuel Grade Solvent
We would end up with 2.25 tank trucks per day 365 days a year.
This permit change will allow the 3M Cottage Grove Hazardous Waste Incinerator to become one of the largest Hazardous Waste Incinerators in the country. If the additional non-3M waste is added to the 62,400,000 lb average processed between 2002 and 2008, at 5,000 Btu per pound they could burn 142,400,000 pounds and at the 12,000 Btu per pound they could burn 95,700,000. The permit also exempts law enforcement waste as part of the 400,000 million Btu, so it would be in addition to the totals listed.
How does this compare to other commercial incinerators? Aptus Hazardous Waste Incinerator in Knolls, Utah burns 60,000,000 pounds per year and is designated as a major Hazardous Waste Incinerator. It is located 25 miles from a town or permanent human habitation. Annual precipitation is 6 inches and relative humidity is 10%. No rivers or streams are within 40 miles of the facility.
Clean Harbors Aragonite Hazardous Waste Incinerator is located in Tooele, Utah. It has a 140 million Btu slagging kiln and processes 100,000,000 pounds per year. Closest resident is in Grantsville, Utah 34 miles away. Annual precipitation is 6- 12 inches.
WTI Hazardous Waste Incinerator is located in East Liverpool, Ohio. The Von Roll incinerator is similar to the 3M Cottage Grove Hazardous Waste Incinerator. It claims to be one of the largest in the world burning 120,000,000 pounds per year.
We have been told by the MPCA that this proposal will help meet the EPA RCRA goals and it has been implied that the current method of disposal of the proposed non-3M Fuel Grade Liquid Hazardous Waste was not adequate. If you look at the RCRA website, waste minimization is the primary goal and it is hard to understand how by burning this waste for free creates an incentive for the waste generators to spend time or money on waste minimization.
If the WRR fuel grade liquid hazardous waste is sent to 3M Cottage Grove hazardous Waste Incinerator so they can use less clean burning natural gas, the current recipient, Continental Cement Company, will have to burn coal as a fuel. How this can be viewed as a positive for the environment?
Again we ask, what is the real reason for the permit change? To the Coalition it appears that some Quid Pro Quo agreement was reached between 3M, MPCA, and Minnesota Law Enforcement. Everyone would benefit except the citizens.
Community Awareness and Emergency Response - Citizens rights under EPCRA
Citizens have a right to know what is being emitted into their environment and to have worst case scenarios identified. There should be detailed modeling when a major change is being made in a Hazardous Waste Incinerator to insure Community Awareness and Emergency Response issues have been addressed.
We have been told the waste is similar to what 3M currently processes. WRR blends still bottoms and incoming materials to produce supplemental fuel for cement kilns. A fuel blender's goal is to create a blend with each of the regulated contaminants as close to the EPA upper limit as possible, but without violating the upper limit. This approach controls the remainder of the wastes left in the blend tank so that the probability of being able to accept virtually any future load is maximized. This is not similar to current 3M fuel grade liquid hazardous waste.
This has been presented to the community as a harmless solvent based material similar to what you have around your house. This has been a disservice to the community and minimizes the intent of EPCRA. Does the WRR material present an increased risk to the community? There have been two major fires at WRR. One fire occurred in 2007 and another fire in 2010 which required shelter in place to be initiated. It appears that both were no fault type issues.
With this permit modification 3M Cottage Grove Hazardous Waste Incinerator will become one of the largest in the country. It should be regulated as such. Hazardous Waste Incinerators present a significant risk to a community. The potential impact from operations and potential emergencies should not be minimized during the permit process. We understand that Homeland Security has not let the Risk Management Worst Case Scenario be made public on a national basis, but local Community Awareness and Emergency Response still needs to be addressed. To be told that no paperwork exists on 3M, MPCA, and Law Enforcement Waste would mean a "What If" exercise was not done. Also, in the FOIA information on the non-3M waste it does not appear that a "What If" exercise was done. What will be the average inventory level in 3M's 200,000 gallon storage tank if non-3M material is included? A Table Top exercise to understand notification of the citizens in a cell phone age should be clearly documented and the residents should understand what to do.
Clear Line of Sight on Accountability and Responsibility - is the MPCA thinking long term?
The current permit restricts bringing in waste from non-3M facilities and should not be changed. 3M manages waste streams from the purchase of raw materials all the way to the final disposal of the waste. This is kind of like a chain of custody - the company should know what is in the waste and about any changes in raw material. Even the bulk liquid waste that currently comes into Cottage Grove is from a process that has a well defined formula. That has given 3M knowledge when material needed to be incinerated. The regulated hazardous waste that is being proposed will come from a fuel blender. They take in regulated hazardous waste from dozens of small generators. Some is reclaimed and reused. When it can longer be reclaimed it is mixed with the residue from the bottom of the stills to increase fuel value. The residue will contain organics, metals, and other contaminants. When you propose to bring in material from another company you lose this chain of custody, compromise accountability and responsibility.
The Metropolitan Council is currently engaged in a lawsuit with 3M on Pfcs. The Metropolitan Council states that if they need to make upgrades in their waste water treatment plants 3M should pay for those because of the ground water contamination. 3M has stated it should not be responsible because they were not the only producer of Pfcs. If 20 years from now, another unexpected environmental contamination issue should occur as a result of the 3M Cottage Grove Hazardous Waste Incinerator as the permit stands today, 3M would be responsible.
Will there be another material found in the environment like Pfcs from incineration?
Who will be responsible if 3M takes in non-3M Hazardous Waste? Would it end up in litigation like the current lawsuit filed by the Metropolitan Council??
If the State of Minnesota uses the 3M Cottage Grove Hazardous Waste Incinerator to burn Law Enforcement Waste for free, would the State of Minnesota be a Defendant or the Prosecutor? Is this a conflict of interest?
3M needs MPCA approval to transfer the permit if the 3M Cottage Grove Hazardous Waste Incinerator were to be sold. If the State of Minnesota uses the 3M Cottage Grove Hazardous Waste Incinerator to burn waste for free will this be a factor in the decision to let 3M sell or shut it down? Is this a conflict of interest?
Will the burning of waste for free for the State of Minnesota be expanded over time? Should there be a sunset clause that allows either party to terminate this agreement at which time it would be removed from the permit? If the State stopped burning waste in the 3M Incinerator who would be accountable for and responsible for future liabilities?
One thing is painfully obvious and it came out loud and clear at the MPCA public information meeting - there is nothing in this permit change for the citizens of Cottage Grove and the surrounding river valley except more pollution. The communities where 3M has shut down incinerators have benefited with less pollution. It now comes to Cottage Grove. The communities where 3M has reduced pollution and hazardous materials in their manufacturing plants will have benefited with less pollution. Cottage Grove would get more pollution with the non-3M waste. The communities around the state of Minnesota that have Meth labs and drug waste will benefit. Cottage Grove will get more pollution. This is not a case of NIMBY for the Coalition. This is a case where our backyard (the river valley) is already full. It is contaminated and the State of Minnesota is suing 3M for environmental damage. How in good conscience could anyone say this permit is a good thing to do, a wise thing to do, or a moral thing to do?
We hope you have seen that the Coalition is a competent organization. We are not experts in the steps of the permitting process and rely on our consultant. If the MPCA has any concerns on how or what we have done, please let us know. To date we believe we have followed all the correct steps in the permitting process and incurred expense to meet the dates.
February 18, 2011 we filed our comments to the NPDES permit and petitioned for a Contested Case Hearing. We have never heard back from the MPCA.
April 9, 2012 we submitted an EAW petition for the 3M Cottage Grove Hazardous Waste Incinerator.
April 20, 2012 we filed our comments on the Air and RCRA permits
April 20, 2012 we requested this meeting
April 23, 2012 we petitioned for a Contested Case Hearing on the Air and RCRA permits
To date we have filed 45 pages with the MPCA on the permits. It is interesting that this is 45 more pages of documentation than exists for the discussion and negotiations that took place between 3M, the MPCA, and Minnesota Law Enforcement on the scope, safety, environmental impact, community awareness, and emergency response requirements on the potential impact of burning confiscated drug waste at the 3M Hazardous Waste Incinerator in Cottage Grove.
As we stated in the letter requesting this meeting, we stand ready to work with the MPCA in its effort to meet its mission:
The MPCA mission is to work with Minnesotans to protect, conserve and improve our environment and enhance our quality of life.
Thank you for your patience. I am sure our board members and the MPCA would now like to make comments.
©2012 Alan Muller