3M Mismanages Waste

Cottage Grove MN (5/26/2022) – The Minnesota Pollution Control Agency (MPCA) today announced its findings of an enforcement investigation against 3M that addressed a series of hazardous waste violations at the company’s facility in Cottage Grove, Minnesota. The investigation began in June 2020.

According to the investigation:

In 1996, 2006, 2012-2014, 2017-2018, and 2020-2021, 3M inaccurately identified hazardous waste sent to its incinerator as non-hazardous waste.

Between 2015 and 2020, over the course of 109 weeks, 3M failed to have a certified third-party laboratory independently verify the accuracy of the incinerator laboratory’s analysis, as required by its permit.

From 2014 to 2020, 3M failed to conduct verification on more than 1,800 waste stream profiles for mercury, lead, nickel, cadmium, arsenic, and other hazardous materials to ensure the waste did not exceed limits.

Since 2016, 3M failed to require two third parties that sent waste to the Cottage Grove incinerator to submit comprehensive data for arsenic, PCBs, lead, mercury and other hazardous materials.

3M stored approximately 1,300 containers of hazardous waste in unapproved areas, 650 of which were stored for longer than the one-year limit.

3M reported six releases from compromised storage containers over a period of six months.

The MPCA first became aware of these specific issues at the company’s Cottage Grove campus in 2020. The agency’s two-yearlong investigation revealed violations dating back to 1996, with all but one violation taking place at the hazardous waste storage and incineration site. As required by the permit, air monitoring at the site is ongoing and shared with the EPA. Based on monitoring data, it does not appear the incineration of the hazardous materials related to this investigation exceeded limits and resulted in violation of 3M’s air permits.

As part of the enforcement action, 3M is required to pay a $2,844,694 civil penalty and has completed 24 corrective actions to ensure that the facility is operating in accordance with rules and its permit.

Corrective actions included:

Increasing independent analysis verification with other state-certified labs and waste stream profile verification.
Increasing container storage inspections.
Storing hazardous waste in compliance with state rules and its permit, keeping records on site, and evaluating all waste streams generated on site.

The Cottage Grove facility had stored and incinerated hazardous waste from all its operations in North America until it discontinued operation on December 31, 2021.

In May 2021, the MPCA announced a separate hazardous waste investigation at this same facility in Cottage Grove. The investigation found one container of hydrofluoric acid, an extremely toxic chemical compound, releasing gases into the air. An additional 901 hazardous waste containers containing hydrofluoric acid, some with bulging barrel lids, were stored throughout the Cottage Grove facility and at risk of further releases. 3M failed to immediately notify the MPCA of an excessive and abnormal unpermitted emission that may cause air pollution that endangers human health. As a result of the 2021 investigation, 3M agreed to pay a civil penalty of $80,000 and make several corrective measures.

Link to Stipulation agreement: https://www.pca.state.mn.us/sites/default/files/w-hw3-73a.pdf

Matt Croaston, 651-757-2690